Federal Economic Update - Fall 2020

On November 30, 2020, the fall economic update was presented by Finance Minister Chrystia Freeland. Many new income tax and sales tax measures and updates to COVID-19 measures were announced, as detailed below.

Income Tax Measures

The Canada Child Benefit

The Canada Child Benefit (CCB) is a non-taxable benefit that is paid monthly and provides support for eligible families with children under the age of 18. In order to provide immediate support for families with young children, the Government proposes to amend the Income Tax Act to provide, in 2021, four payments of:

• $300 per child under the age of six to families entitled to the CCB with family net income equal to or less than $120,000, and
• $150 per child under the age of six to families entitled to the CCB with family net income above $120,000.

The first of these amounts would be payable after the enabling legislation is passed, with subsequent amounts payable in the first month of each remaining quarter (i.e., at the end of April, July and October 2021). These amounts would be payable to the individual who receives a CCB amount for a particular month, i.e., the primary caregiver of the child in January, April, July or October 2021.

If a family's adjusted net income is too high to receive the CCB in that month, they would not receive a quarterly amount. For the amounts that would be payable in the first quarter of 2021 and April, a family's adjusted net income is based on the family's net income in 2019. For the months of July and October, a family's adjusted net income is based on the family's net income in 2020. For example, if a family's net income is $130,000 for 2019 and $70,000 for 2020, the parent entitled to the CCB in respect of a child under the age of six would receive the additional quarterly amount of $150 once enabling legislation is passed and at the end of April and $300 at the end of July and October.

Note that these additional quarterly amounts are subject to the same rules as regular CCB payments.

Registered Disability Savings Plan

Budget 2019 proposed changes to the Registered Disability Savings Plan (RDSP) regime for beneficiaries with episodic disabilities, essentially to remove the time limitation on the period that an RDSP may remain open after a beneficiary becomes ineligible for the DTC and to eliminate the requirement for medical certification that the beneficiary is likely to again become eligible for the DTC in the future in order for the plan to remain open. Budget 2019 proposed that these changes would apply as of January 1, 2021. It also proposed that until the coming-into-force date of the measure, RDSP issuers would not be required to close an RDSP solely because the beneficiary is no longer eligible for the DTC.

In the economic update, the Government proposed to maintain the implementation timeline for this measure. Any excess repayments of Canada Disability Savings Grants and Canada Disability Savings Bonds in respect of withdrawals made after 2020 and before the measure is enacted would be returned to a beneficiary’s RDSP following enactment.

To ensure more equitable treatment, the Government proposes an additional modification to the formula put forward in Budget 2019 for determining the amount of grants and bonds held back from a withdrawal, in the following manner:

• For a beneficiary who ceases to be eligible for the DTC after the calendar year in which they attain 49 years of age, the reference period for the assistance holdback amount would begin on January 1 of the year that is 10 years before the year in which the event (e.g., withdrawal or plan closure) occurs and end on the day preceding the day on which the beneficiary ceased to be eligible for the DTC. The assistance holdback amount would be equal to the total amount of grants and bonds paid into the RDSP during that period, less any repayments of those amounts.

RDSP issuers will have the normal flexibilities with respect to time to implement these changes.

Employee Stock Options

Budget 2019 announced the Government’s intention to move forward with changes to limit the benefit of the employee stock option deduction for high-income individuals employed at large, long-established, mature firms. The Government released draft legislative proposals in June 2019 and consulted stakeholders on the characteristics of start-up, emerging and scale-up corporations for the purpose of exempting such corporations from the new employee stock option tax rules.

A $200,000 limit is proposed on the amount of employee stock options that may vest in an employee in a calendar year and continue to qualify for the stock option deduction. For the purpose of the $200,000 limit, the amount of employee stock options that may vest in any calendar year would be considered to be equal to the fair market value of the underlying shares at the time the options are granted. An option vests when it first becomes exercisable. The determination of when an option vests would be made at the time the option is granted. If the year in which the option vests is not clear, the option would be considered to vest on a pro-rata basis over the term of the agreement, up to a five-year period.

The $200,000 limit on the amount of employee stock options that may vest in any calendar year and qualify for the stock option deduction would generally apply to all stock option agreements between the employee and the employer or any corporation that does not deal at arm's length with the employer. If an individual has two or more employers that deal at arm's length with each other, the individual would have a separate $200,000 limit for each of those employers.

If the amount of stock options that may vest in a year exceeds $200,000, those employee stock options granted first would be the first to qualify for the stock option deduction. Where an employee has a number of identical stock options and some qualify for the existing tax treatment while others are subject to the new tax treatment, the employee would be considered to first exercise the stock options qualifying for the existing tax treatment.

Tax Treatment for Employees

Where an employee exercises an employee stock option that is in excess of the $200,000 limit, the difference between the fair market value of the share at the time the option is exercised and the amount paid by the employee to acquire the share would be treated as a taxable employment benefit. The full amount of the employment benefit would be included in the income of the employee for the year the option is exercised, consistent with the treatment of other forms of employment income. The employee would not be entitled to the stock option deduction in respect of this employment benefit.

Donations of Publicly Listed Shares Acquired Under an Employee Stock Option Agreement

Under the current tax rules, if an employee donates to a qualified donee, such as a registered charity, a publicly listed share (or the cash proceeds from the sale of a publicly listed share) acquired under an employee stock option agreement within 30 days of the exercise of the option, the employee may be eligible for an additional deduction equal to one-half of the employee stock option benefit. As a result, where both the stock option deduction and the additional deduction in respect of a qualifying donation are available, the entire employee stock option benefit is effectively excluded from income.
If an employee donates a publicly listed share acquired under a stock option that is in excess of the $200,000 limit, the employee could be eligible for the charitable donation tax credit but would not be eligible for any deduction on any associated employee stock option benefit. Any capital gain that has accrued since the share was acquired under the stock option agreement would continue to be eligible for the full exemption from capital gains tax, subject to the existing rules.

Tax Treatment for Employers

For employee stock options in excess of the $200,000 limit, the employer would be entitled to an income tax deduction in respect of the stock option benefit included in the employee’s income. The deduction may be claimed in the taxation year of the employer that includes the day on which the employee exercised the stock option.

There are currently a number of conditions that must be met for an employee to be eligible for the stock option deduction. These conditions would be required to be met for an employer to be entitled to a deduction under the new rules.

Employers subject to the new rules would be able to choose whether to grant employee stock options under the existing tax treatment, up to the $200,000 limit per employee, or whether to grant employee stock options under the new tax treatment (i.e., ineligible for the employee stock option deduction, and instead eligible for a deduction for corporate income tax purposes).

Employers subject to the new rules would need to ensure compliance with respect to the $200,000 limit. This would include a requirement that an employer notify its employees in writing whether options granted are subject to the new tax treatment. In addition, employers would be required to notify the Canada Revenue Agency if the options granted are subject to the new tax treatment.

Which Employers are Subject to the New Rules?

The new rules would apply to employers that are corporations or mutual fund trusts.

Employers that are Canadian-controlled private corporations (CCPCs) would generally not be subject to the new rules.

Further, in recognition of the fact that some non-CCPCs could be start-ups, emerging or scale-up companies, non-CCPC employers whose annual gross revenue does not exceed $500 million would generally not be subject to the new rules.

• For an employer that is a member of a corporate group that prepares consolidated financial statements, gross revenue would be as reported in the most recent consolidated annual financial statements of the group presented to shareholders, or unitholders, prior to the date that the stock option is granted, at the highest level of consolidation. Consolidated financial statements are financial statements in which the assets, liabilities, income, expenses and cash flows of the members of the group are presented as those of a single entity, and are prepared in accordance with the generally accepted accounting principles of the jurisdiction in which they are reported.
• For an employer that is not a member of such a corporate group, gross revenue would be as reported in the employer’s most recent annual financial statements prepared in accordance with generally accepted accounting principles and presented to shareholders, or unitholders, prior to the date that the stock option is granted (or that would have been reported if such financial statements had been prepared in accordance with generally accepted accounting principles).

Where employee stock options to acquire shares or units of an entity that is not the employer are granted to an employee, the new rules would apply in respect of those options if that entity does not deal at arm’s length with the employer and either the entity or the employer is subject to the new rules.

Employers that are not subject to the new rules would not be permitted to opt in to the new employee stock option tax rules.

These new tax rules would apply to employee stock options granted after June 2021. The existing rules would continue to apply to options granted before July 2021 (including qualifying options granted after June 2021 that replace options granted before July 2021). 

Simplifying the Home Office Expense Deduction

To simplify the process of claiming home office expense deductions for both taxpayers and businesses, the CRA will allow employees working from home in 2020 due to COVID-19 with modest expenses to claim up to $400, based on the amount of time working from home, without the need to track detailed expenses, and will generally not request that people provide a signed form from their employers. This measure will help taxpayers access deductions they are entitled to receive and simplify the tax filing process. Further detail will be communicated by the CRA in the coming weeks.

Sales Tax Measures

GST/HST Relief on Face Masks and Face Shields

The Government proposes to introduce a temporary GST/HST zero-rating applicable to the supply of certain face masks and face shield.

This measure would apply to supplies made after December 6, 2020 and is proposed to only be in effect until their use is no longer broadly recommended by public health officials for the COVID-19 pandemic.

Application of the GST/HST in Relation to E-commerce Supplies

The current sales tax system often results in the GST/HST not being collected on online purchases from non-resident vendors or made through digital platforms. The non-collection of the GST/HST presents equity, economic and fiscal concerns, and it places physical and online retailers operating in Canada at a competitive disadvantage in comparison to non-resident vendors.

The Government proposed a few changes (see below) to the GST/HST system in order to ensure that the GST/HST applies in a fair and effective manner to the growing digital economy.

GST/HST on Cross-Border Digital Products and Cross-Border Services

The Government proposes that non-resident vendors supplying services or digital products to consumers in Canada be required to register for GST/HST purposes and to collect and remit the tax to the CRA on their taxable supplies to Canadian consumers.

It is also proposed that distribution platform operators be generally required to register for the GST/HST and to collect and remit the tax on the supplies that these platforms facilitate of services or digital products of non-resident vendors to Canadians.

A simplified GST/HST registration and remittance framework would be available to non-resident vendors and non-resident distribution platform operators that are not carrying on business in Canada. This program would include the following key features:

• A simplified online registration and remittance system with an online portal available to the non-resident vendors of services or digital products and non-resident distribution platform operators;
• Non-resident vendors or non-resident distribution platform operators would only be required to collect and remit the GST/HST on the supply of services and digital products made to Canadian consumers. For these purposes, an entity or person that is registered for GST/HST purposes would be considered a business and any other entity or person would be considered a consumer;
• With certain exceptions, non-resident vendors and non-resident distribution platform operators would be required to collect the GST/HST on their supplies of services or digital products if the consumer’s usual place of residence is in Canada. The usual place of residence would be determinable based on a few factors, such as the home address, billing address, Internet Protocol address of the device used, bank or payment information, and subscriber identification module (SIM) card that relate to the recipient. Generally, a consumer’s usual place of residence would be considered to be in Canada when two or more of these indicators identify Canada as the consumer’s normal location or residence.
• The non-resident vendors and non-resident distribution platform operators registered under the simplified GST/HST registration process would not be able to claim input tax credits to recover the GST/HST paid on business inputs. The non-resident vendors or non-resident distribution platform operators that wish to claim such input tax credits may register under the normal GST/HST registration process; and
• These rules apply for non-resident vendors and non-resident distribution platform operators making supplies of services or digital products to Canadians under the following circumstances:

• For a non-resident vendor, if their total taxable supplies of services or digital products made to consumers in Canada exceed, or are expected to exceed, $30,000 over a 12-month period; and
• For a non-resident distribution platform operator, if their total taxable supplies of services or digital products made to consumers in Canada, including the supplies of services or digital products of non-resident vendors to consumers in Canada that the operator facilitates, exceed, or are expected to exceed, $30,000 over a 12-month period.

Purchases by GST/HST Registered Businesses

A GST/HST registered business will continue to be required to self-assess and remit the GST/HST on its purchases of services and digital products from non-resident vendors and non-resident distribution platform operators, unless the purchase is for use exclusively in the business’s commercial activities.

A penalty would apply if a person provides a GST/HST registration number to a non-resident vendor or non-resident distribution platform operation to evade, or attempt to evade, tax on the purchase of services or digital products acquired for personal consumption.

If a GST/HST registered business provides its GST/HST registration number and is nevertheless charged the GST/HST, the business would be able to request a refund from the non-resident vendor and non-resident distribution platform operator. Any GST/HST paid by the registered business in such cases would not be recoverable by claiming an input tax credit or by filing a tax paid in error claim.

Coming into Force

The proposed new rules would apply to supplies of cross-border services or digital products to the extent that the consideration for the supply becomes due on or after July 1, 2021, or is paid on or after that day without having become due.

GST/HST on Goods Supplied through Fulfillment Warehouses

General

Non-resident vendors are increasingly selling goods to Canadians through digital platforms that facilitate sales of third-party vendors, which we will refer as “distribution platforms”. These distribution platforms may also store the goods of third-party vendors in fulfillment warehouses in Canada and ship these goods to purchaser in Canada after the goods have been sold to through the platforms. The GST/HST is not consistently charged on the final price for the goods when they are subsequently sold to Canadians through distributions platforms and fulfillment warehouses located in Canada.

Although these goods are situated in Canada at the time of sale, there is generally no requirement under the current rules for the non-resident vendor, or distribution platform facilitating the sale, to collect or remit the GST/HST when the goods are sold to a purchaser in Canada.

This situation creates a competitive inequity for resident vendors and represents a gap in the GST/HST rules.

Therefore, the Government proposes to:

• Require distribution platform operators to register under the normal GST/HST rules and to collect and remit the GST/HST in respect of sales of goods that are located in fulfillment warehouses in Canada (or shipped from a place in Canada to a purchaser in Canada), when those sales are made by non-registered vendors through distribution platforms;
• Require non-resident vendors to register under the normal GST/HST rules and to collect and remit the GST/HST in respect of sales of goods that are located in fulfillment warehouses in Canada (or shipped from a place in Canada to a purchaser in Canada), when those sales are made by the non-resident vendors on their own; and
• Require fulfillment businesses in Canada to notify the CRA that they are carrying on a fulfillment business and to maintain records regarding their non-resident clients and the goods they store on behalf of their non-resident clients.

The following framework outlines how the GST/HST would apply under this proposal:

• The goods imported into Canada will continue to be subject to applicable duties and taxes on the value of the goods at the time of importation;
• Distribution platform operators (whether resident or not) would be deemed to be the supplier in respect of sales they facilitate by non-registered vendors (whether resident or not) of goods that are located in fulfillment warehouses in Canada or shipped from a place in Canada to a purchaser in Canada. Distribution platform operators would be required to collect and remit the GST/HST on the final sale price of the goods for which they were deemed to be the supplier;
• Distribution platform operators (whether resident or not) would be required to register under the normal GST/HST rules and to collect and remit the GST/HST if their total qualifying supplies, including those made through their platforms by non-registered third-party vendors, to purchasers in Canada that are not registered for the GST/HST exceed or are expected to exceed $30,000 over a 12-month period;
• Registered distribution platform operators would be eligible to claim input tax credits in respect of the tax paid at the border by non-registered third-party vendors that import their goods into Canada and sell their goods through distribution platforms. Registered third-party vendors would be eligible, as under the existing GST/HST rules, to claim input tax credits in respect of the tax paid on inputs used in their commercial activities, including tax paid at the border;
• Distribution platform operators would be deemed to not have made a supply to the non-registered third-party vendor of services relating to the deemed supply of goods made through the platform;
• This proposal would be designed to ensure that it would not conflict with the existing drop shipment rules, which are a key way in which non-registered non-residents obtain GST/HST relief in commercial activities. GST/HST relief would be provided under the drop shipment rules where a non-registered non-resident provides a certificate to a service provider or vendor of goods acknowledging that a registered distribution platform operator was deemed to sell the goods and required to collect tax;
• Distribution platform operators would be required to report information to the CRA on the third-party vendors using their platforms;
• Non-resident vendors that make sales of goods without the use of a distribution platform would also be required to register under the normal GST/HST rules if their total qualifying supplies to purchasers in Canada that are not registered for the GST/HST exceed or are expected to exceed $30,000 over a 12-month period; and
• Persons carrying on a fulfillment business in Canada would be required to notify the CRA that they are carrying on a fulfillment business and maintain certain records on their non-resident clients.

Coming into Force

The proposed new rules would apply to supplies made on or after July 1, 2021, and supplies made before July 1, 2021 if all of the consideration is payable on or after July 1, 2021.

GST/HST on Platform-based Short-Term Accommodation

General

The GST/HST applies to supplies of short-term accommodation (for instance, rental to a person for a period of less than one month).

The short-term accommodation sector increasingly includes individual property owners renting out their residences or other residential property they own, or rooms within their residences or other residential property they own. These types of rentals are often made through digital platforms. Under the current GST/HST rules, the property owner is generally considered to be making the supply of the short-term accommodation.

Persons that have annual taxable supplies of $30,000 or less are generally not required to register for and collect the GST/HST. However, other property owners that operate on a larger scale are required to register for and collect the GST/HST, but may not be aware of these requirements.

The digital platforms that facilitate these rentals are often not responsible for accounting for the supply of the short-term accommodation under the current GST/HST rules.

The Government proposes to apply the GST/HST on all supplies of short-term accommodation in Canada facilitated through a digital platform. The GST/HST would be required to be collected and remitted on short-term accommodations supplied in Canada through an accommodation platform by either the property owner or the accommodation platform operator as follows:  

• The property owner (or person responsible for providing the accommodation), where the owner (or person responsible for providing the accommodation) is registered for the GST/HST; and
• The accommodation platform operator, where the property owner (or person responsible for providing the accommodation) is not registered for the GST/HST.

The following framework outlines how the GST/HST would apply under this proposal:

• The GST/HST would apply to all taxable supplies of short-term accommodation in Canada that are facilitated by an accommodation platform operator;
• Underlying third-party suppliers of short-term accommodation who are registered for the GST/HST would continue to be required to charge, collect and remit the GST/HST on their supplies that are facilitated by an accommodation platform operator;
• The operator of an accommodation platform that facilitates the supply of short-term accommodation in Canada by third parties that are not registered for the GST/HST would be deemed to be the supplier of the accommodation for purposes of the GST/HST;
• An accommodation platform operator that facilitates or expects to facilitate over a 12-month period more than $30,000 in taxable supplies of short-term accommodation in Canada where the underlying third-party suppliers of the accommodation are not registered for the GST/HST would be required to register for and collect and remit the GST/HST on such supplies;
• Some accommodation platform operators may charge service fees to non-registered third-party property owners/suppliers in respect of the supplies of short-term accommodation in Canada that they facilitate. Accommodation platform operators registered for the GST/HST would be deemed to not have made a supply of services to the non-registered third-party property owner/suppliers of short-term accommodation in Canada relating to facilitating the supply of the accommodation. This proposed deeming rule recognizes that non-registered third-party property owners/suppliers are unable to claim input tax credits in respect of the tax paid on inputs used in their commercial activities;
• Some accommodation platform operators may charge the guest who is acquiring the short-term accommodation a service fee or commission for the services they provide in helping the guest to find and book an accommodation and in facilitating the transactions between the guest and the third-party property owner/supplier. The GST/HST would be applicable on the platform’s guest fee to a guest that is in respect of taxable short-term accommodation property situated in Canada, and the rate of GST/HST would be based on the location of the property in Canada; and
• Accommodation platform operators would be required to maintain records and report information to the CRA, including information on the underlying third-party property owners/suppliers using their platforms.

To facilitate compliance with these requirements, a simplified GST/HST registration and remittance framework would be available to non-resident accommodation platform operators that are not carrying on business in Canada.

The proposed new simplified system would include the following key features:

• A simplified online registration and remittance system with an online portal available to the non-resident accommodation platform operators that facilitate taxable supplies of short-term accommodation in Canada where the underlying third-party property owners/suppliers of the accommodation are not registered for the GST/HST;
• Non-resident accommodation platform operators would only be required to collect and remit the GST/HST on the supplies of taxable short-term accommodation in Canada made to consumers. For these purposes, an entity or person that is registered for GST/HST purposes would be considered a business and any other entity or person would be considered a consumer; and
• There will be no input tax credits available to recover the GST/HST paid on business inputs with respect to the non-resident accommodation platform operators registered under the simplified GST/HST registration process. The non-resident vendors or non-resident distribution platform operators that wish to claim such input tax credits may register under the normal GST/HST registration process.

Purchases by GST/HST Registered Businesses

A GST/HST registered business will continue to be required to self-assess and remit the GST/HST on its purchases of short-term accommodation facilitated by a non-resident accommodation platform operator that is registered under the simplified GST/HST registration/remittance system, unless the purchase is for use exclusively in the business’s commercial activities.

A penalty would apply if a person provides a GST/HST registration number to a non-resident accommodation platform operator to evade, or attempt to evade, tax on the purchase of short-term accommodation in Canada acquired for personal consumption.

If a GST/HST registered business provides its GST/HST registration number to such a non-resident accommodation platform operator and is nevertheless charged the GST/HST on the supply of short-term accommodation, the business would be able to request a refund of the tax from the non-resident accommodation platform operator. Any GST/HST paid by the registered business in such cases would not be recoverable by claiming an input tax credit or by filing a tax paid in error claim.

Coming into Force

The proposed new rules would apply to supplies of short-term accommodation in Canada to the extent that the consideration for the supply becomes due on or after July 1, 2021, or is paid on or after that day without having become due.

COVID-19 Measures

Canada Emergency Wage Subsidy (CEWS)

Details regarding the CEWS have been legislated through December 19, 2020. Today, the Federal Government provided details on the parameters of the CEWS that are proposed to apply for the following periods:

• Period 11 – December 20, 2020 to January 16, 2021
• Period 12 – January 17 to February 13, 2021
• Period 13 – February 14 to March 13, 2021

The CEWS legislation provides for a separate CEWS calculation for active employees and for furloughed employees.

Active employees

For active employees, the CEWS legislation provides for two CEWS rates, the base CEWS and the top-up CEWS. The base CEWS is based on the reduction in revenue in the current month. The maximum rate for the base CEWS varies depending on the claim period the employer is applying for.

The top-up CEWS of up to 25% is also determined based the reduction in revenue in the current month, subject to a safe harbour rule applicable to periods 8, 9 and 10. An employer must experience a revenue drop in excess of 50% in order to claim the top-up CEWS.

The maximum combined base CEWS and top-up CEWS rate is set at 65% for the current claim period, which ends on December 19, 2020.

Proposed changes

The Federal Government is proposing that the maximum base CEWS rate continues to be 40% for periods 11 to 13.

Regarding the top-up CEWS, it is proposed to increase the rate to 35% for periods 11 to 13. The combined maximum base CEWS and top-up CEWS could reach 75%. The table below illustrates the base and top-up CEWS for periods 11 to 13.

Furloughed employees

For periods 9 and 10, the CEWS legislation provides that the CEWS for furloughed employees is aligned with the benefits provided through Employment Insurance (EI). The Federal Government proposes that the CEWS for furloughed employees continues to be aligned with benefits available under EI. Therefore, the subsidy per week in respect of an arm’s length employee (or a non-arm’s length employee who received pre-crisis remuneration for the relevant period) would be the lesser of:

• the amount of eligible remuneration paid in respect of the week; or,
• if the employee receives remuneration of $500 or more in respect of the week, the greater of
  • $500 and
  • 55% of pre-crisis remuneration for the employee, up to a maximum subsidy amount of $595.

Employers will also continue to be entitled to claim under the wage subsidy their portion of contributions in respect of the Canada Pension Plan, EI, the Quebec Pension Plan and the Quebec Parental Insurance Plan in respect of furloughed employees.

Reference periods

Currently, the CEWS legislation provides that the decline revenue of an employer is determined either:

• By comparing the employer’s revenues in a month with the revenues in the same month in 2019 (the year-over-year approach); or
• By comparing the employer’s revenues in a month with the average of its January and February 2020 revenues (the alternative approach).

Also, a deeming rule provides that an employer’s decline in revenues for any particular qualifying period is the greater of its decline in revenues for the particular qualifying period and the immediately preceding qualifying period.

The Federal Government is proposing reference periods for determining an eligible employer’s decline in revenues for the qualifying periods 11 to 13, as per the below table:

Employers that had chosen to use the general approach for prior periods would continue to use that approach. Similarly, employers that had chosen to use the alternative approach would continue to use the alternative approach.

All the other parameters of the CEWS program would remain unchanged.

Finally, the Federal Government mentioned that the details for the CEWS for any periods beyond March 13, 2021 will be proposed at a later date.

Canada Emergency Rent Subsidy

The rate structure for the Canada Emergency Rent Subsidy has been extended to March 13, 2021. The actual program goes until June 2021. However, rates and structures for post March 13, 2021 have not yet been announced.

If you have any questions with respect to the above, please contact your Crowe BGK advisor.