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March News Update

Craig Carlini, CPA – ccarlini@rubino.com

Dave Albert, CPA  – dalbert@rubino.com

Lisa Hahn, CPA – lhahn@rubino.com

Robert Tempchin, CPA – rtempchin@rubino.com

David Burnstein, JD, CPA – dburnstein@rubino.com

Kay Vollans, CPA – kvollans@rubino.com

Vikita Shah, EA – vshah@rubino.com

This newsletter highlights some of the most recent federal and state tax updates in the month of March.

Federal Tax Updates

Continuation from the prior newsletter:

  • IRS update on reporting digital assets

On January 24, 2023, the IRS reminded taxpayers that they must answer a digital asset question and report all digital asset-related income when they file their 2022 federal income tax return. For more information and continued updates on digital asset reporting, please click on the link here.

  • IRS updates factsheet on Tax Credits for Electric Vehicles

On February 3, 2023, the IRS updated frequently asked questions related to new, previously owned, and qualified commercial clean vehicle credits. For more information and continued updates on tax credits for electric vehicles, please click on this link.

National Taxpayer Advocate delivers 2022 Annual Report

The Advocate’s report to Congress assessed taxpayer service during 2022. It identified the ten most serious problems taxpayers were experiencing in their dealings with the IRS and made recommendations to address those problems. This year’s report outlined specific initiatives for the IRS to include in its plan how the additional funding it received in the Inflation Reduction Act will be spent. The report designed to help the IRS improve its online operations.

The taxpayer advocate reviewed the IRS website along with the website of 41 states which have an individual income tax, the District of Columbia, Puerto Rico, and three Countries, Canada, Australia, and the United Kingdom. It identified three areas where the IRS website lagged behind those of the other taxing authorities and suggested possible improvements.

Research and Development Tax Credit

Prior to the Tax Cuts and Jobs Act of 2017 (TCJA), research and experimental (R&E) expenses changed Section 174 of the Internal Revenue Code. As a result of this change, taxpayers are now required to capitalize Section 174 R&E expenditures incurred after 12/31/2021 and amortize them over 5 years. (Qualifying foreign expenditures are required to be amortized over 15 years).

Section 174 R&E expenses can be broken down into two categories. The first category, direct research expenses, are items that qualify for the R&D tax credit under IRC Section 41 such as wages, supplies, and materials. The second category, indirect research expenses, are those items that are incidental to the research being done such as rent, utilities, and travel. Apart from the rare exception, most Section 41 expenses are Section 174 expenses.

Many businesses have R&E costs that will be subject to the new capitalization requirements. In addition to the costs to develop a new product, costs necessary for the improvement of a product fall under this new rule. Additionally, costs related to the discovery of information subsequently used to develop or improve a product should be capitalized.

Effects for 2022:

Normally, a change from expensing costs to capitalizing and amortizing costs would require a taxpayer to file Form 3115, Application for Change in Accounting Method. To make the transition to this new method (somewhat) less complicated, the IRS issued Revenue Procedure 2023-11 which outlines simplified filing procedures for businesses adopting this new law. Taxpayers can file a statement with their original return, for the first tax year beginning after December 31, 2021, which includes a few key pieces of information and avoid filing a complicated Form 3115. However, the simplified filing procedures are not allowed for businesses who delay adoption of Section 174 capitalization.

This change in the treatment of R&E expenses will come as a surprise to many businesses. The timing issues resulting from the capitalization and amortization of expenses, rather than the immediate deduction of them, could result in higher tax liabilities in the short term. This could also cause cash flow issues for some businesses.

What can be done to mitigate the tax impact?

  • As a result of the new law, many businesses will need to adjust their accounting system to record qualified R & E expenses separately from non-qualified and indirect costs. A critical look at how expenses are recorded may help reduce tax liabilities.
  • Some businesses may benefit from a Research and Development Tax Credit Study under Section 41 (or they may have R&D tax credit carryovers which can now be utilized).
  • Qualifying businesses which have taxable income as a result of capitalizing R&E costs may be eligible for the Section 199A (QBI) deduction to lower total tax.

The Section 174 capitalization requirement could be repealed, or its enactment could be delayed. Businesses should consider filing extensions for the 2022 tax year to see if changes are forthcoming.

The new law is complex and nuanced. If you think your business will be affected, please contact your tax advisor.

Tax-exempt status for non-profit

Three Years Can Go By Quickly – Don’t Lose Your Tax-Exempt Status

Tax-exempt organizations faced too many obstacles as a result of the pandemic – widespread impact to mission activities, inability to hold in-person conferences, and to continue good works for the public and/or member organizations, and so much more. In many cases, organizations also had to quickly pivot from having staff members in office to having them to work remotely. These changes impacted both the field and back-office operations.

As we all make our way back to the office or settle into the “new” normal, many organizations are finding themselves in an unfortunate position of not having filed 990s during the pandemic. This could potentially result in the organization’s loss of its tax-exempt status. Regrettably, the IRS has not provided any of the penalty relief provisions for late filed 990s which it extended to other forms and filing entities in the fall of 2022. To complicate the issue, if the IRS has sent correspondence to an organization that no longer receives mail at their former address or they could not timely access the mail, the tax-exempt organization could be unaware of this unlucky predicament.

Organizations that do not file for three consecutive years automatically lose their tax-exempt status. The revocation is effective on the original filing due date of the third annual return or notice. If an organization’s tax-exempt status is automatically revoked, it is no longer exempt from federal income tax. An automatically revoked organization is not eligible to receive tax-deductible contributions and will be removed from the cumulative list of tax-exempt organizations, Publication 78. State and local laws may affect an organization that loses its tax-exempt status as well. The law prohibits the IRS from undoing a proper automatic revocation and does not provide for an appeal process. An automatically revoked organization must apply to have its status reinstated, even if the organization was not originally required to file an application for exemption.

The IRS publishes the list of organizations whose tax-exempt status was automatically revoked of failure to file a required Form 990, 990-EZ, 990-PF or Form 990-N (e-Postcard) for three consecutive years. IRS updates the list monthly. Check to make sure your organization is in good standing and has not been automatically revoked: https://apps.irs.gov/app/eos/.

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With the Rubino Team, Anything Is Possible

JORDAN TEMPCHIN, CPA

Jordan has been in the accounting profession since 1968 and joined the firm in 2019 when Jordan Tempchin & Associates merged with Rubino. He brings over 50 years of tax experience to the table and specializes in corporate and partnership taxes, along with fiduciary tax returns. Jordan is now retiring.

MAXWELL BORENSTEIN, CPA

Max has been in the accounting profession since 2012 and specializes in preparing tax returns. He specializes in individual, business, and nonprofit tax returns.

FILIBERT OUEDRAOGO, CPA

Filibert has been in the accounting profession since 2015 and specializes in providing audit and accounting services to nonprofit organizations. He regularly analyzes and reconciles balance sheet accounts and prepares financial statements. Filibert executes various types of transaction testing which include disbursements, payrolls, and journal entries. On a regular basis, he performs walkthroughs with clients to better understand their system of recording.

Filibert also has experience assessing, observing, and testing internal control procedures and compliance with laws, regulations, and grant requirements.

CIARA GAGLIANO, CPA

Ciara has been working in public accounting since 2013 and is a supervisor in our public housing authority practice. She specializes in auditing, accounting, and consulting services for housing authorities. In addition, Ciara has experience performing Single Audits in accordance with OMB Uniform Grant Guidance for governmental and nonprofit entities, including the audits of HUD-funded and insured projects.

AMY KRIZ, CPA

Amy has been in the accounting profession since 2000. Amy specializes in providing consulting and accounting services to nonprofit organizations. She is knowledgeable and skilled in the day-to-day nonprofit financial operations management. She has a strong history of achieving both financial and non-financial business goals and has helped organizations achieve their vision and mission.

LISA HAHN, CPA

Lisa specializes in tax planning, tax compliance, and tax preparation services for high-net-worth clients, flow-through structures, and corporations. She also assists businesses with the tax requirements of their initial registration and maintains ongoing tax compliance.

Lisa regularly researches tax law and develops strategic plans to minimize clients’ income and estate tax liabilities.

DAVID ALBERT, CPA, Esq.

Dave is responsible for managing his diverse tax practice, including high-income individuals, small businesses, estates, and trusts.

Dave has been in the accounting profession since 1977. With more than 45 years of experience in public accounting, Dave brings a level of excellence that our clients rely on.

CRAIG CARLINI, CPA, CFP

Craig brings over 30 years of experience and specializes in finding strategies to minimize tax burdens for his clients. He is responsible for management of the tax, wealth management and business consulting practice, practice development and client services.

He has extensive experience providing proactive, creative tax and investment advice to law firms, government contractors, medical practices, lobbying firms, and high net worth individuals.

Craig also provides consulting on business acquisition, compensation planning, business restructuring, and reengineering.

PATRICK CURTIS, CPA, CGMA

Patrick has been in the accounting profession since 1999 and currently leads Rubino’s outsourced accounting practice. He has extensive experience designing, integrating, and implementing accounting systems for nonprofit organizations, government contractors, medical practices, and small to medium sized businesses. Patrick is also an engagement partner in the firm’s consulting and assurance practice.

Patrick is a well-known and respected expert in compliance matters arising out of Federal awards. He has a broad range of experience supporting Federal Agency efforts to take disallowances and the development and support of other compliance related findings arising out of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.

SCOTT FLAHERTY, CPA

Scott serves as Rubino’s Administrative Partner and has been in the accounting profession since 1993. He provides audit, review, and consulting services and works extensively with nonprofit organizations, government contractors, and small to medium sized businesses. Scott uses his expertise to assist clients navigating through the complex web of rules and regulations to maintain compliance and improve performance and efficiency. He values working closely with clients not only during the audit period, but over the course of the entire year to help them through various challenges that may arise.

ROBERT HINZ, CPA

Bob has been in the accounting profession since 1987 and joined the firm in 1991. With over 35 years of experience serving a wide range of clients, including both large and small nonprofit organizations, government contractors, and construction companies, he is responsible for recurring client services, including the management of audit and consulting engagements. These engagements have included the specialized requirements of audits performed under the Uniform Guidance. Bob also performs audits of 401(k) and 403(b) pension plans.

In addition to his client responsibilities, Bob is a member of Rubino’s Quality Control team.

LOUIS RUBINO, CPA, JD

Lou is the co-founder of Rubino and has led Rubino to becoming one of the top accounting firms in the DC metropolitan area. He has been in the accounting profession since 1967.

Lou consults on government contract procurement and regulatory compliance issues and construction litigation support matters. He also provides general business consulting services to Rubino’s clients. He has assisted government agencies and private owners, as well as contractors, with litigation support services, which range from complete preparation or review of claims for damages to consulting and expert testimony on specific cost accounting issues and compliance matters.

ROBERT TEMPCHIN, CPA

Robert has been in the accounting profession since 2000 and joined the firm in 2019 when Jordan Tempchin & Associates merged with Rubino. With over 20 years of experience serving a wide range of clients in different areas, including individual tax planning and preparation, corporate tax, bookkeeping services, and estate and tax planning, Robert strives to provide the innovative approach that our clients need to reach their business and personal goals.

DAWIT NEGARI, CPA, CFE, CGFM, MBA

Dawit has been in the accounting profession since 1995 and specializes in providing audit, consulting, and advisory services to nonprofit organizations and government contractors. He provides expert guidance on matters related to generally accepted accounting principles, Uniform Guidance, and employee benefit plan audits.

As a member of Rubino’s Quality Control Team, Dawit assists with the firm’s audit quality and services and is responsible for researching and implementing new accounting and auditing standards.

ROBERT KOZAK, CPA

Bob has an excess of 40 years’ experience which includes working five years with a national accounting firm in their auditing department and heading up the audit practice with a large local firm.

He is well versed in the requirements of the United States Department of Housing and Urban Development (HUD), Virginia Housing Development Authority (VHDA), and other state regulated real estate, and has over 30 years of experience in auditing nonprofit organizations, including Uniform Guidance Single Audits (formerly known as OMB Circular A-133 Single Audits), and compliance with Government Auditing Standards.

Bob is also thoroughly familiar with auditing real estate projects receiving an allocation of Low-Income Housing Tax Credits under Section 42 of the Internal Revenue Code. He has worked with most federal financial assistance programs and Community Development Block Grant Programs.

BRUCE POLLEKOFF, CPA

Bruce brings over 40 years of experience which includes working five years with a national firm’s tax department.

His experience includes working with high-net-worth individuals, Partnerships, S-Corporations, C-Corporations, Estate, Trust, and nonprofit organizations. He also specializes in advising business clients on their financial and operating planning needs.

GERALD GOLDMAN, CPA

Jerry provides accounting, assurance, consulting, and tax services to a wide range of industries, including real estate development, brokerage and management companies, commercial and multifamily real estate properties, professional service firms, construction, and nonprofit organizations. Jerry’s consulting services extend to succession planning, outbound business planning and tax controversy management.

SHANNON GELLMAN

Shannon has been providing taxation services since 1995 and specializes in individual, corporate, and nonprofit tax returns. She is an Enrolled Agent who has technical expertise in the field of taxation and prepares high-level tax returns, oversees the preparation of Employee Benefit returns, and assists with the preparation and management of the nonprofit returns. She puts years of public accounting experience to use by developing her expertise in working with nonprofit clients. Shannon provides a wide range of services to nonprofit clients that includes assistance with compliance for Federal and State reporting.

DEBORAH KAYE-PENNOCK, MSA

Debbie specializes in providing consulting and accounting services to government contractors, medical providers, nonprofit organizations, and small businesses. She offers clients practical accounting experience with an emphasis on financial operations and management, cost accounting and accounting system design.

SUSANNA GORTON CUCCIA, CPA

Susanna has been in the accounting profession since 1998 and specializes in providing audit and tax services. Her experience primarily focuses on auditing regulated real estate including the construction and development of low-income housing and low-income housing tax credit entities as well as nonprofit organizations.

CARL SERGI, CPA

Carl specializes in providing tax services including planning, compliance and representation before the Internal Revenue Service and other agencies. Carl’s experience includes corporate taxation (regular C-Corp, S-Corp), estate, gift, fiduciary, individual, and partnership taxation. He services real estate developers (homebuilders, commercial and residential), real estate operators and lessors, professional service corporations, restaurants, and wholesale and retail trades.

PATTI O’MALLEY, CPA

Patty has provided tax and accounting services to nonprofits for over 30 years. With an emphasis on accountability, Patty helps nonprofit organizations meet their financial reporting, operational, and federal and state filing requirements. Due to her extensive experience working with nonprofit organizations in all areas of tax preparation and planning, Patty understands the vigorous reporting requirements of the Form 990.
Patty is mostly retired, but still works with Rubino on an as needed part-time basis.

ELAINE RULKIEWICZ, CPA

Elaine performs tax planning services and provides compliance advice for a variety of businesses and individuals in the federal tax area as well as assistance with state tax reporting, IRS audits, and foreign tax matters.

Her responsibilities include supervision and review of corporate, partnership, and individual tax returns. She also provides tax consulting and planning services for a variety of small businesses.

KAY VOLLANS, CPA

Kay has been in the accounting profession since 2006. She has focused most of her career on providing tax compliance and consulting to nonprofit organizations in the greater D.C. area. Kay enjoys working with a variety of tax-exempt organizations, including local and national charities, social welfare organizations, business and trade associations, and private foundations, and partners with clients to help them understand and meet their federal, state, and foreign filing requirements.

She has extensive experience with Form 990 reporting and consults with clients on various tax matters, including employment, state and local, and international issues.

DANIEL BORNE

Dan has been in the accounting profession since 2006 and has extensive experience performing audits, accounting, and consulting services. Since joining Rubino, Dan has devoted most of his time, providing auditing, consulting, and tax services to nonprofit and government contractors and their related regulatory and compliance requirements. He also performs audits of employee benefit plans.

KYLE GOOD, CPA

Kyle has been in the accounting profession since 2006. He started his career as an auditor with Rubino. After gaining many years of experience, Kyle went into the industry to work as a controller at a government contractor. Kyle has since returned to Rubino and now fills a financial leadership role for many nonprofit organizations and closely held companies. As a Senior Manager he is ultimately responsible for overseeing the development and implementation of accounting systems with a strong emphasis on internal controls.

He provides financial reports and analysis, business operation consulting, management of grant funds from federal and private foundation sources, and cash flow planning. Kyle also supports client needs with budget systems, projections, audit and tax return support. His experience working with these organizations provides Kyle with relevant insight into how strong financial leadership contributes to the overall success of the organization.

DANIELLE YUE, CPA

Danielle is a senior manager in Rubino’s Tax Service Practice. In this role, she works with high-net-worth clients and specializes in business pass through taxes and individual income tax compliance. She has extensive experience in the healthcare, real estate markets, and hospitality. With over 15 years of experience, Danielle holds business consulting knowledge combined with corporate tax expertise making her a unique asset to clients and Rubino team.

ALLAN KITCHEN, CPA

Allan has been in the accounting profession since 1980 and leads Rubino’s Public Housing Authority audit practice. His industry experience includes public housing authorities and other governmental entities, the affordable housing industry (tax credit developments, HUD and other government assisted housing), residential real estate, manufacturing, distribution, construction contractors, and the nonprofit sector. He has provided clients with a variety of services, including internal control structure, keeping them current on government required standards and financial statement audits. Further, Allan is experienced in meeting the requirements of GAGAS, HUD audits, and Uniform Guidance.

KARIS CALL, CPA

Karis has been in the accounting profession since 2011 and leads Rubino’s nonprofit audit practice.

Karis takes pride in leading Rubino’s nonprofit audit practice because she truly values tax-exempt organizations and recognizes their unique environment. She has extensive experience in financial and compliance audits, including Single Audits, reviews, and compilations. In her role, Karis evaluates process-level and entity-wide controls and related audit risk areas. She emphasizes communication with clients throughout the audit process on complex audit issues that may arise and comply with regulations and standards. In addition, Karis provides strategic supervision to audit staff. She also has helped organizations put in best practices in accordance with federal laws and governing state legislation.

MELANIE ERICKSON, CPA, MBA

Melanie has over 25 years of professional taxation experience. Having begun her career as a revenue agent with the Internal Revenue Service, she brings a unique perspective on taxation to clients. She assists a wide variety of clients including passthrough entities, C Corporations, sole proprietorships, individuals, trusts, and estates. Melanie also has expertise in multi-state organizations and tax dispute resolution. Melanie’s industry experience includes real estate, restaurants, professional services, and more. Melanie joins Rubino after holding an impressive career with the likes of the Internal Revenue Service, Berlin Ramos & Company, and Cherry Bekaert, LLC.

MATTHEW MURAKAMI, CPA

Matthew has been in the accounting profession since 2013, with a primary focus on performing audit services for nonprofit organizations and government contractors. He has also performed numerous audits of pension plans and audits in accordance with the provisions of OMB Uniform Gran Guidance.

Matthew’s primary responsibilities include daily oversight of face-to-face work with clients, facilitation of the performance of fieldwork, and maintenance of efficient timelines and due dates for submitting required deliverables to clients. These responsibilities provide for an intricate understanding of each client’s environment, internal controls, capabilities, risks, and susceptibilities, which, in turn, allow for beneficial value-added recommendations and solutions.

BRYAN O’DONNELL, EA

Bryan is a Tax Supervisor at Rubino and has specialized in tax accounting since 2009. Before then, Bryan spent 22 years as a federal internal auditor and investigator. He specializes in corporate, partnership, nonprofit, trust, estate, and individual tax preparation and compliance. Bryan has extensive expertise in individual taxation for high-net-worth individuals, commercial real estate and real estate partnerships tax accounting, tax and retirement planning, tax research, and tax accounting systems. Bryan also specializes in client development and relations.

CHANH TRAN, CPA, MST

Chanh started his career in tax working for a privately held multibillion-dollar company. He joined a regional public accounting firm in 2004 and has been in public accounting since. He has provided tax compliance, planning, and consulting services to his privately and publicly held business clients in a wide range of industries.

AMANDA LIN

Amanda started her career at a privately held technology company then joined Rubino in 2018. In her current role, she specializes in accounting activities, financial reporting, business operation consulting, and payroll services to nonprofit organizations and closely held businesses of varying sizes. She also supports our clients’ needs with budget systems, projections, and audit support.

SANDRA FRANKS JERNUDD, CGFM, DFCP

Sandy has been in the accounting profession since 1980 and primarily provides accounting services for Public Housing Authorities and clients in the renewable energy industry. Sandy’s experience working with project companies and tax credits makes her a natural fit in this role. Her role at Rubino has recently been expanded to include the management of nonprofit and for-profit clients.

Prior to joining Rubino, Sandy was the comptroller of a public housing authority.

JINGXIAN JI, CPA

Jingxian has been in the accounting profession since 2016. She has experience planning, executing, and completing financial statement audits, review, and compilation engagements for nonprofit organizations, government contractors, private companies, employee benefit plans, and Single Audits as required by Uniform Grant Guidance. Jingxian works to facilitate a streamlined and efficient audit approach that aims to minimize hassles to the client and maximize audit value. Jingxian also has experience identifying, assessing, observing, and testing internal control procedures and compliance with laws, regulations, and grant requirements.

DANIELLE ARMSTRONG, CF APMP

Danielle is a proposal specialist with more than 15 years of experience. As a member of the Rubino team, she supports each line of business and champions the firm’s proposal and pursuit efforts. Vital to Rubino’s business development, Danielle leads the proposal process, gathering and creating material to compile solutions that meet and exceed the client’s needs. She ensures that our proposal process continually keeps up with innovation and best practices.

KIRSTEN COOMBS, CPA

Kirsten has been in the accounting profession since 1997. She has experience working in public accounting for a range of medical, Informational Technology, and non-profit organizations. As a Corporate Finance professional, Kirsten has implemented financial systems and ERPs for small-to-large companies, startups to Fortune 500 businesses.

She knows the importance of needs-based, fact gathering that individually assesses an entity’s business. She looks at system implementations as opportunities not to improve just the software a company uses, but a chance to provide efficiencies in workflow in the Accounting, Finance, and Human Resources departments. Kirsten has managed external consultants for systems implementations and worked with third-party software to incorporate data from multiple sources.

MARINA SEGURA, CPA

Marina has been in the accounting profession since 2000. She has experience providing audit services to a variety of clients including law firms, real estate, hospitality, investment managers, and benefit plans. She began her audit career with Deloitte and then moved to PricewaterhouseCoopers. Most recently, prior to joining the firm, she worked on internal audit department to help with the transitioning from private to public of a resort company.

SCHINTERRIA TAYLOR

Schinterria specializes in providing accounting activities, financial reporting, business operation consulting, and payroll services for nonprofit and public sector organizations.

THERESA RAY

Terri specializes in providing accounting activities, financial reporting, business operation consulting, and payroll services for nonprofit and public sector organizations. Prior to joining Rubino in 2019, Terri worked in the affordable housing industry and has a thorough knowledge of the housing choice voucher program.

GREG KINOSZ, CPA

Greg has been in the accounting profession since 2012 and specializes in preparing tax returns. With an emphasis on accountability, Greg assists organizations in meeting their financial reporting, operational and federal and state filing requirements. In his interactions with his clients, he reviews the required tax returns, provides technical expertise, manages audit engagements, and performs a wide variety of accounting functions including management consulting and advisory services.

VIKITA SHAH, CA

Vikita has been in the accounting profession since 2011 and specializes in international tax. She has worked on many international tax assignments involving tax treaties, OECD BEPS projects, global/regional holding company structures, tax-efficient financing, cash repatriation and redeployment structures, and intellectual property income migration.

She has also worked on US tax compliance projects with focus on international forms and filings like Forms 5471, 8858, 8865 and 8992 and has experience analyzing GILTI and FDII tax efficiencies. In addition, Vikita has experience with FIRPTA tax filing requirements and BE-10 survey forms.

KRISTEN MIRSKY, JD

Kristen is responsible for providing clients with a variety of tax-compliance services, including individual and fiduciary return preparation, tax projections, and substantive responses to IRS and state tax authority inquiries. As a practicing attorney she specializes in estate planning, wealth preservation and probate administration.

LI-AN WANG, CPA

Ann has been in the accounting profession since 2017, with a primary focus on performing audit services. She regularly assists in performing company-wide annual risk assessment, financial statements audits, reviews, and preparations of financial statements as well as audit reports for government contractors, private companies, nonprofit organizations, and Single Audits as required by Uniform Grant Guidance. Additionally, she provides 401(k) plan audit support services in accordance with the relevant regulations, government polices/procedures and client polices/procedures.

LINDSEY AKRE, CPA

Lindsey has been in the accounting profession since 2013.

Lindsey joined Rubino in 2021 following nine years of experience in public accounting providing client services in both the tax and assurance fields. In her current role, Lindsey supports client needs in various areas including accounting system transitions, accounting activities, business operation consulting, financial reporting, projections, and audit support.”

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