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Thread: ACA and TPR

  1. #1
    CPAFMA Member Larry Sheftel's Avatar
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    ACA and TPR

    Is anyone doing any special kind of invoicing to their clients for either the ACA or the Tangible Property Regs (TPR)? We are putting a line on all of our invoices and charging our clients for our advanced knowledge of what is going on. Is anyone else doing something?>

  2. #2
    CPAFMA Member
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    Do you do that for every client even if the issues don't apply? If I look at this from the client's perspective I would be pretty annoyed by that..... I would be thinking, what the heck, aren't you supposed to have 'advanced knowledge' of everything accounting-related -- why am I being charged extra for this one issue?

    I know our tax dept did put a mention into the engagement letters that if the client turned out to need Form 3115 work that could incur an additional fee. Is that the same as the TPR you mentioned? Beats me, I'm not a tax accountant! :-)

  3. #3
    CPAFMA Member Larry Sheftel's Avatar
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    We will delete the line of the invoice if it doesn't apply. We are going to hit all the individuals with the ACA, but know that we will need to not invoice the children. We know we might miss some clients and this might cause some headaches, but we want to make sure we maximize our billings....Here is the exact wording that we are going to use.

    Additional time incurred in preparation of 2014 tax return related to Affordable Care Act and Tangible Property Regulations per IRS requirements

  4. #4
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    We aren't doing a standard billing statement or charge but have included warnings about additional fees in earlier communications re: ACA. Fortunately most of our clients have insurance and had it for all 12 months. If we had to do that form for many clients we'd need a mental hospital!? We have billed for ACA compliance and consulting throughout the year and have a separate billing code for that. Thank goodness the Rev Proc eliminated the need to file 3115 for most of our clients. Our firm is pretty niched so we have sort of a template 3115 that we use for the ones that don't meet the exception.

  5. #5
    CPAFMA Member Donna Malarkey's Avatar
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    We are not charging our clients, but... it is sickening how much time has been wasted on both. Multiple having to attend webinar after webinar, each one with a different answer as the IRS changes their position. I will mention it our managing shareholder, just in case he wants to consider this. It will be interesting to see what others are doing. Thanks for posting the question!

  6. #6
    CPAFMA Member Sharon Trabbic's Avatar
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    Hi everyone,
    We spent quite a bit of time understanding the new regs and explaining it to our team, and money on software as well. We're forging ahead to complete a 3115 for clients only with tangible assets. We notified them in early January about the new regs and how it would be good for them, and also told them what the expense would be to complete this form on their behalf this year. We are using a flat rate to help absorb the upfront costs, which is proportionate based on their list of assets and their revenue. It's a separate project and separate line item on the invoice so that we can remember next year when we compare WIP and invoicing.
    Sharon L. Trabbic, COO, William Vaughan Company, Maumee, Ohio

  7. #7
    CPAFMA Member Larry Sheftel's Avatar
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    Just because of all the compliance necessary, regardless of whether 3115 will be filed or not, are you trying to recapture any of the time associated with making sure that your clients are in compliance with the new regs? Thanks

  8. #8
    CPAFMA Member
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    We have been recapturing on a client by client basis. We bill by activity and project so we created those items. We have had some clients have an issue with it but for the most part with a short conversation any issues have been resolved. It is a PIA but what part of our business isn't.

    We did invest quite a bit of time understanding and training staff on how to handle and address the forms and preparation. Additionally it was not in our control it is IRS required item and we passed it off as that and billed accordingly.

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