< Previous20Tax Tools Dealerships Can Use to Help Improve Cash FlowBy Bill Sturges, Corinne Baughman, Martin Hughes, and Lewis Fisher; CPAs During these uncertain times of the COVID-19 pandemic, many dealerships face closures, decreased sales, and difficulties with inventory management, among other challenges. Under these circumstances, maintaining your dealership’s operations and staff are top of mind. Most of the following strategies available to dealerships offer a number of opportunities to increase current year losses and the recovery of taxes paid in prior years. QUICK REFUNDS AVAILABLE FOR C CORPORATIONSDuring times of business disruption, C corporations could be looking to quickly generate increased cash flow.For a C corporation whose estimated tax deposits significantly exceed its anticipated tax liability, one option is to file a quick refund claim before its original tax return filing date.CriteriaThis opportunity is only available for C corporations if their anticipated overpayment is at least:• 10% of its expected tax liability• $500Application ProcessTo apply for the quick refund claim, calendar-year corporations must file Form 4466 no later than July 15, 2020. The IRS will act on the form within 45 days from the filing date. Some states could also allow a quick refund of income taxes.If the refund requested by the corporation is greater than the refund due when the return is filed, the corporation will be liable to pay the additional tax and interest when returns are filed.NET OPERATING LOSS CARRYBACKS AND CARRYFORWARDSThe Coronavirus Aid, Relief, and Economic Security (CARES) Act allows a taxpayer to decide whether to carry NOLs back or carry them forward; an election can be made for each separate tax year in 2018, 2019, and 2020.Most dealerships will benefit by choosing to carry the loss back because tax reform in 2018—also known as the Tax Cuts and Jobs Act (TCJA)—lowered the corporate tax rate from 35% to 21% at the start of that year. Instead of receiving $21 of benefit for every $100 of loss carried forward, a corporation could receive $35 with a carryback—a permanent difference.Add discussion of similar results for losses at the individual level: Most dealerships are not C-corps so individual rate differences would be more meaningful.Prior to the TCJA, NOL carrybacks for corporations often resulted in alternative minimum tax credits as opposed to a full refund on prior taxes paid. The CARES Act now allows taxpayers to accelerate refunds of these credits to one year from the prior four years under the TCJA.If the taxpayer has an opportunity to carry back a 2018, 2019, or 2020 loss, it could be beneficial to maximize the loss to the extent there’s income and associated taxes to recover during the five-year carryback. A downturn in the economy offers a number of unique opportunities to enhance such losses.ELECTING TO TREAT CERTAIN 2020 LOSSES AS 2019 DEDUCTIONSTaxpayers could make an election to treat certain losses arising from a presidentially-declared disaster as having occurred in the prior tax year. This election results in all eligible losses directly linked to the disaster being deductible on the prior year’s return.21Such losses must be evidenced by a closed and completed transaction that isn’t reimbursed by insurance, but can include the following:• Losses from inventory sold below cost• Inventory donations to non-charities• Costs associated with closures such as lease origination or lease improvements• Previously capitalized costs on abandoned expansion plans The election and corresponding deduction will require the following documentation:• Identification and calculation of the disaster losses after giving consideration to insurance or other financial indemnities• Factual analysis establishing the cause and effect of the disaster to the lossesIt’s important to note this provision is typically available in the context of a natural disaster, such as a wildfire or hurricane, and limitedto geographic area. Guidance is needed to understand its implications in a pandemic. The choice to make the election should be part of an overall cash flow strategy that considers the enhanced carryback and quick refund opportunities.INVENTORY STRATEGYBelow is an inventory strategy where tax deductions can be accelerated. Deduction for Subnormal GoodsA tax deduction for the write-down of subnormal finished goods could be allowed if careful steps are followed. While many dealerships record inventory obsolescence reserve on their generally accepted accounting principles (GAAP) financial statements, these reserves aren’t typically deductible for tax until realized.If steps are taken near to and following year-end, a deduction for subnormal goods is permitted for income tax purposes. The lower inventory valuation must be substantiated by providing evidence of the following:• Actual offerings• Actual sales• Actual contract cancellationsThe IRS guidance has clarified that taxpayers may not deduct the same inventory basis twice and need to choose between the above tax purposes until the asset is actually written off. However, there are a number of situations in which partial worthlessness of a debt can be identified and partially charged-off prior to a balance sheet write-off.With proper analysis and documentation, the taxpayer could, in effect, recognize a portion of the bad debt reserve as an expense for tax purposes at a significantly earlier point.COST SEGREGATION STUDIES AND QUALIFIED IMPROVEMENTSCost segregation is a tax deferral strategy that frontloads depreciation deductions into the early years of ownership. It does so by segregating cost components of a building into the proper asset classifications and recovery periods for federal and state income tax purposes.The end result is significantly shorter tax lives—five-year, seven-year, and 15-year depreciation periods—that can lead to bonus depreciation eligibility rather than the standard 39-year depreciation periods.In addition, the CARES Act included the long-awaited technical correction to qualified improvement property (QIP).Any improvement made by the taxpayer to the interior portion of nonresidential real property after the building was first placed in service—excluding improvements to enlarge the building, any elevator or escalator, or the internal structural framework of the building—could be considered a QIP.The fix is retroactive so taxpayers that placed QIP in service in 2018 are able to treat such property as 15-year property eligible for bonus deprecation. Depending on when QIP was placed in service, the taxpayer may need to file for an accounting method change.TAX ACCOUNTING METHOD CHANGES Accelerating deductions and deferring revenue in stable tax environments is always good tax planning. These timing differences can create significant cash flow benefits for taxpayers. However, when combined with the recent opportunity to carryback net operating losses, these planning strategies can also create significant permanent differences for such taxpayers.The following are typical opportunities where a taxpayer can change their method of accounting to accelerate deductions or defer revenue through an accounting method change:• Accelerate the deduction of certain prepayments, including services, advertising, catalogue costs, insurance, and property taxes22• Deferral of revenue for cash received from gift cards• Accelerating the deduction for website development costs• Used vehicle lower of cost or market methods• Apply 263A safe harbor elections to reduce capitalized costs in inventory• Advertising and trade discount inventory elections for new vehicle inventory• New vehicle last in, first out (LIFO) inventory methods• Buy here, pay here accounting methodsAccounting method changes also offer the opportunity for taxpayers using an impermissible method of accounting to correct the method and defer cost of the correction over four years while protecting against prior year audit adjustments.INCREASE OF SECTION 163(J) LIMITThe CARES Act increases the Section 163(j) interest deduction limitation from 30% to 50% of adjusted taxable income (ATI) for tax years beginning in 2019 or 2020. Partnerships, however, remain subject to the 30% limitation for tax years beginning in 2019.Taxpayers eligible for the 50% limitation could elect to use the 30% limitation instead. In addition, all taxpayers, including partnerships, may elect to use their ATI for the tax year beginning in 2019 to compute their Section 163(j) interest deduction limitation for the tax year beginning in 2020. This favorable election should be beneficial for many businesses dealing with a downturn from the pandemic.Partners that are allocated excess business interest expense (EBIE) for tax years beginning in 2019 are able to deduct 50% of that EBIE in tax years beginning in 2020 while the remaining 50% of the 2019 EBIE is subject to the normal Section 163(j) rules. The expense is carried forward to tax years for which the partner is allocated sufficient excess taxable income (ETI) from the partnership.SUSPENSION OF EXCESS BUSINESS LOSS RULE THROUGH 2020The CARES Act modifies excess business loss (EBL) rules for noncorporate taxpayers by postponing the effective date of the provision to tax years beginning after 2020. EBL rules previously limited the amount of business losses against other income.Those taxpayers that filed 2018 tax returns reflecting an EBL are presumably eligible to file an amended tax return to remove any imposed EBL limitation and receive a refund.2020 PAYROLL PLANNING OPPORTUNITIESThe CARES Act provides several opportunities to defer or receive a permanent credit against payroll. The opportunities are listed below.Payment of Employer Payroll Taxes DeferredEmployers can defer payment for the employer portion of payroll taxes incurred on March 27, 2020, through December 31, 2020.If deferred, the employer would instead pay 50% of this amount by December 31, 2021, and the remaining 50% by December 31, 2022. The eligible payroll taxes are the employer’s portion of Social Security taxes—6.2% of an employee’s wages.Employers that have loans forgiven under the Payroll Protection Program (PPP) loan—Section 1102 of the CARES Act—aren’t eligible. However, qualifying payroll amounts may be deferred up until the date the loans are actually forgiven.Employee Retention Credit for EmployersEligible employers may claim a credit against Social Security taxes for each qualifying calendar quarter, equal to 50% of qualified wages, and up to $10,000 for all quarters per employee. The maximum credit could be worth up to $5,000 per eligible employee.Eligible employers operating a business during 2020 must have experienced either:• A partial or full suspension of the operation of their trade or business during the calendar quarter due to governmental orders that limited commerce, travel, or group meetings due to COVID-19.• A significant decline in gross receipts from 2019.Employers who benefit from the PPP loan aren’t eligible. Also, qualified wages don’t include amounts paid for the sick leave credit or family leave credit enacted by the Families First Coronavirus Response Act (FFCRA) described below.The Families First Coronavirus Response ActThe Families First Coronavirus Response Act (FFCRA), enacted on March 18, 2020, requires certain employers to provide employees with paid sick leave or expanded family and medical leave for specific reasons related to COVID-19. Additionally, the FFCRA provides temporary tax credits for impacted employers and self-employed individuals for emergency paid leave.23These provisions will apply from April 1, 2020, to December 31, 2020.Under the FFCRA, covered employers required to provide paid sick leave—or expanded family and medical leave for specific reasons related to COVID-19—will qualify for an immediate dollar-for-dollar tax offset against the payroll taxes they paid each quarter.PROPERTY TAXTaxpayers with ownership of real estate, inventories, equipment, facilities, offices, storefronts, or other property will generally be assessed property tax on a specified taxable value. In many jurisdictions, this taxable value can be reviewed for potential opportunities in order to assess proper liability.OpportunitiesA review of valuation, asset life classification, inventory exemptions, intangible property, and other cost savings opportunities could provide opportunity to:• Reduce current year expenses• Recoup overpaid tax• Reduce future expendituresNext StepsHere’s a list of considerations if you’re thinking about reviewing your property tax liability:• Review your property tax values and consider a real estate valuation study to substantiate any reduction in value.• Examine asset listings with jurisdictions by completing an asset review that will assess taxability of intangible property, reporting of out-of-service assets, and proper trending factors.• Review filings for Freeport Exemptions that can reduce property tax on inventory holdings.TAX CREDIT FOR ALTERNATIVE FUELSPresident Trump signed the Further Consolidated Appropriations Act into law on December 17, 2019, which retroactively restored the refundable federal tax credit for the sale or use of alternative fuels, including propane. The credit—which originally expired on December 31, 2017—is now extended for fuel sold or used through December 31, 2020.IRS Notice 2020-8 provides procedural guidance for 2018 and 2019 refund claims. Taxpayers may claim a one-time credit for fuels sold or used during 2018 and 2019 without having to file amended returns. This may provide substantial benefit to many businesses. Claims must be filed by August 11, 2020. Taxpayers must be registered with the IRS, make detailed calculations, and ensure they have documentation for claims. CALIFORNIA CONSIDERATIONSSales and Use TaxEffective March 30, 2020, all taxpayers who file a return with a liability of less than $1 million will receive an automatic extension to July 31, 2020, to file and pay the collected sales tax reimbursements from their customers. This means returns for the first quarter of 2020 and March 2020 filings originally due April 30, 2020, are extended automatically for an additional 90 days. 2019 annual use tax returns, originally due April 15, 2020, received an automatic extension to July 31, 2020 as well.If your dealership’s liability is $1 million or more, you can still request an extension and relief from penalties and interest that would have applied due to the late filing or late payment of the tax. However, these requests will be approved on a case-by-case basis. Instructions can be located on the CDTFA website.Finally, for business with less than $5 million in taxable sales, interest-free payment plans are available. Check the CDTFA website for more details. Business ConsiderationsBusinesses should be aware that:• The applicable tax return and payment of the sales and use tax in full needs to be completed by July 31, 2020. • Failure to file the return or make the payment of sales and use tax in full at that time will subject the business to interest and penalties after July 31, 2020.• As of May 11, 2020, second quarter and April monthly filing and payment dates haven’t been extended.Businesses should be mindful of using tax collected from their customers for interim operating cash flow needs. The CDTFA isn’t waiving payment of tax. Businesses still have an obligation to remit tax collected from their customers. 24Not all other states have provided relief for either late filing or late payment. You can check the status of your state by visiting its tax collecting agency’s website. Check the date any information was posted to ensure it’s current.Executive Order on California Property TaxGovernor Gavin Newsom issued an executive order on May 6, 2020, suspending the California property tax late filing penalty provisions if property tax returns are filed by May 31, 2020. Since May 31, 2020, falls on a Sunday, any property tax statement mailed and postmarked on or before the next business day, June 1, 2020, will be deemed timely filed.The executive order also extends the property tax payment date for: • All owner-occupied residential real property• Real property owned and operated by a \ qualified small business The small business definition isn’t the same as the definition used for PPP loan eligibility, therefore it may not apply to larger organizations that were considered small businesses due to special carve outs in the CARES Act. Governor Newsom’s order covers all tax jurisdictions within the state.If you’re considering an opportunity to lower property taxes as a result of the market impact of COVID-19, it’s important to understand the lien date, and the time period for which substantial evidence is allowed to support such valuations. In California, March 31 has historically been the latest date that market data is permissible to support valuations for the earlier January 1 lien date. Exceptions exist for certain disasters, but it remains to be seen whether the pandemic will qualify for such an exception. The appeals process in California has historically started on July 2.Business ConsiderationsBusinesses should be aware that if paying real estate taxes are a condition of an existing lease obligation, they should consult their attorneys regarding available options for deferring payment.Note on COVID-19During this unparalleled time, we’re closely monitoring the COVID-19 situation as it evolves so we can provide up-to-date guidance and support to help you combat uncertainty. For regulatory updates, strategies to help cope with subsequent risk, and possible steps to bolster your workforce and organization, please see the following resources:• COVID-19 Implications Resource Page at www.mossadams.com/covid-19-implications• COVID-19 Implications: A Complete Content Map at www.mossadams.com/ covid-19-implications/sitemapCorinne Baughman has practiced public accounting for over 20 years. Her experience includes corporate reorganizations; business owner succession services; buy-sell transactions; entity formation and liquidation; multistate taxation; strategic and operations planning; transactional analysis; and international taxation. Corinne can be reached at (949) 221-4048 or corinne.baughman@mossadams.com.Martin Hughes has practiced public accounting since 1986. He provides assurance and consulting services to privately held and public middle-market clients in the apparel, retail, and manufacturing and distribution industries. He has significant experience with accounting, auditing, and general business and management issues. Martin is also a chartered accountant in Europe. He can be reached at (310) 295-3816 or martin.hughes@mossadams.com. Bill Sturges has been in public accounting and private industry since 1992. He provides tax services to both public and private companies in the service, technology, manufacturing, and retail industries. His specific expertise is in serving business entities on strategic tax planning, FAS 109, mergers and acquisitions, and accounting periods and methods. He can be reached at (310) 481-1218 or bill.sturges@mossadams.com. Lewis Fisher has practiced accounting in the automotive and dealer services industry since 2000. He specializes in providing assurance and consulting services to clients in the transportation business, with a focus on retail automotive companies. Throughout his career, Lewis has worked in retail-facing, corporate, and public accounting positions in the automotive industry. He can be reached at (949) 623-4169 or lewis.fisher@mossadams.com.Assurance, tax, and consulting offered through Moss Adams LLP. Investment advisory services offered through Moss Adams Wealth Advisors LLC. Investment banking offered through Moss Adams Capital LLC.25ASKALISONQ: What is an Internal Revenue Code (IRC) Section 125 plan?A: A Section 125 plan (which most all dealerships have) allows employers to adopt a written plan to let employees elect to pay for certain benefits, including group health plan coverage, on a pre-tax basis through salary reductions. Section 125 also permits employees to contribute pre-tax reductions to an HFSA (Healthcare Flexible Spending Account) or DCAP (Dependent Care Assistance Program) and certain other benefits.Q: Can dealerships allow employees to change Section 125 (also known as cafeteria plans) elections throughout the year?A: Employees generally cannot change plan elections during the year unless they experience a change in status that allows for an election change under specific limited circumstances allowed in IRS regulations. However, as employers have dealt with the COVID-19 outbreak, many questions have arisen as to how the cafeteria plan election rules apply to the many unforeseen circumstances created by the current pandemic.Q: How has COVID-19 affected Midyear Election ChangesA: The COVID-19 public health emergency has created unanticipated changes in the need for or availability of medical care. Some dealerships have been willing to offer employees who initially declined to elect group health coverage another chance to elect health coverage, or to allow employees enrolled in group health coverage to enroll in different health coverage offered by the same employer or drop existing employer sponsored health coverage to enroll in other health coverage not offered by their employer (e.g., coverage offered by their spouse’s employer). A recent IRS Notice allows an employer to amend its cafeteria plan (including limiting the period during which election changes may be made) to allow each employee who is eligible to make salary reduction contributions under the plan to make prospective election changes (including an initial election) during calendar year 2020 regarding employer-sponsored health coverage, a health FSA, or a DCAP, regardless of whether the basis for the election change satisfies the standard change in status criteria in IRS regulations. Q: What are the quick facts about these new changes?A: The IRS specifically will allow employers to amend a cafeteria plan to allow employees to prospectively:• Make a new election for employer-sponsored health coverage, if the employee initially declined to elect employer-sponsored health coverage.• Revoke an existing election for employer-sponsored health coverage and make a new election to enroll in different health coverage sponsored by the same employer (including changing enrollment from self-only coverage to family coverage).• Revoke an existing election for employer-sponsored health coverage, provided that the employee attests in writing that the employee is enrolled, or immediately will enroll, in other health coverage not sponsored by the employer.• Revoke an election, make a new election, or decrease or increase an existing election regarding an HFSA or DCAPEPIC can help your dealership navigate the new challenges facing you and your HR team due to COVID-19.EPIC ranks among the top 15 retail insurance brokers in the United States and is the largest insurer of auto dealers in the state. Alison McCallum has been in the employee benefits industry for over 20 years. She is a Principal with EPIC insurance Brokers and Consultants, the only CNCDA licensed broker. With this partnership EPIC offers unique services available to OCADA dealer members at no cost. If you have questions or would like further information please feel free to contact her at (949) 417-9136 or alison.mccallum@epicbrokers.com.26How to Handle OSHA Investigations Followinga COVID-19 Complaint As of April 17, 2020, Cal/OSHA had received over 1,500 complaints about employers who allegedly failed to provide proper protection during the ongoing pandemic related to the COVID-19 crisis. OSHA’s investigative powers are limited in their ability to fully investigate all these complaints. Cal-OSHA Reporter noted that in the first quarter of 2019, OSHA had investigated only 488 complaints. For 2020, the number of investigations will likely increase. WHAT IS OSHA LOOKING FOR: The regulations that allow OSHA to investigate COVID-19 related complaints at auto dealerships are as follows:Personal Protective Equipment: Personal Protective Equipment (PPE) which require using gloves, eye and face protection, and respiratory protection when job hazards warrant it. When respirators are necessary to protect workers, employers must implement a comprehensive respiratory protection program in accordance with the Respiratory Protection standard. Compliance requires an assessment of hazards and then providing proper PPE that addresses those hazards. PPE must be provided at no cost and employees provided with training in proper usage.Hazard Communication Program: Employers must also protect their workers from exposure to hazardous chemicals used for cleaning and disinfection. Employers should be aware that common sanitizers and sterilizers could contain hazardous chemicals. Where workers are exposed to hazardous chemicals, employers, must comply with this standard. Requirements include a written program, providing SDS, proper labels on containers and training on understanding the hazards related to chemicals in use.General Duty Clause: The clause requires employers to provide each worker “a place of employment, which [is] free from recognized hazards that are causing or are likely to cause death or serious physical harm.” This is literally the catch-all provision that OSHA inspectors can use when no standard seems to be violated.HOW TO HANDLE AN OSHA INSPECTION Inspections are always conducted without advance notice. As a matter of policy, a 20-minute wait for the OSHA inspector prior to the inspection process is considered acceptable. Management can alert all responsible Managers on the premises regarding the presence of OSHA and possible involvement in the inspection process. WHAT DOES THE INSPECTION PROCESS INVOLVE?Inspectors’ Credentials: When the OSHA compliance officer arrives at the establishment, he or she displays official credentials and asks to meet an appropriate employer representative. In the opening conference, the compliance officer explains how the establishment was selected and what the likely scope of the inspection will be. Take written notes during the opening conference and note the scope indicated by the inspector. The compliance officer asks the employer to select an employer representative to accompany the compliance officer during the inspection. This person must stay with the inspector until departure from the company premises. Limitation on OSHA Inspections: OSHA has limitations on inspection authority when visiting a place of employment. OSHA officers may try to expand the scope of inspection during the visit and upon informed consent may proceed to collect evidence that can significantly increase the violations detected and related penalties. Therefore, it is critical that the employer only provide OSHA access to the location that is related to the underlying cause of inspection. Such boundaries must be established during the opening conference with the OSHA officer. In a recent case, the US Court of Appeals limited the scope of inspection available to OSHA. The case involved an employee who was injured while repairing an electrical panel. See USA v. Mar-Jac Poultry, Inc., No. 16-17745 (11th Cir. 2018). The employee was hospitalized triggering a report to OSHA under federal regulations. OSHA inspected the facility and was granted access by the employer to look at the electrical panel area. Upon request, OSHA inspectors were provided Injury Log 300 by the employer. Upon review of Log 300, OSHA filed for a search warrant to investigate other locations at the plant where the injuries as reported on the Log 300 had occurred. The search warrant was granted. Subsequently, the employer filed a motion to vacate the search warrant which was granted by the District Court. OSHA appealed the lower court’s decision to the 11th Circuit Court of Appeals. The appeals court held that logs are merely records of injuries and not proof of OSHA violations. The mereCONCERNED WITH THE COST, COMPLIANCE AND SERVICING OF YOUR DEALERSHIPS’ INSURANCE?EPIC CAN HELP WITH YOUR BENEFIT AND BUSINESS INSURANCE NEEDS• CNCDA's only licensed broker for Health and Business insurance• The largest insurer of auto dealers in the state• The only broker with proprietary products specific to dealerships • 15TH largest brokerage firm in the nationWe know dealerships have specific needs and issues, we are here to help. Please contact us for a free evaluation of your insurance and HR/compliance packages.EPIC IS© EDGEWOOD PARTNERS INSURANCE CENTER | CA LICENSE 0B29370EPICBROKERS.COMAlison McCallum 949.417.9136alison.mccallum@epicbrokers.comEric Kitei 949.417.9145eric.kitei@epicbrokers.comAS THE CNCDA’S ONLY LICENSED BROKER FOR HEALTH AND BUSINESS INSURANCE AND THE LARGEST INSURER OF AUTO DEALERS IN CALIFORNIA, EPIC IS UNIQUELY POISED TO HELPexistence of injuries, the court noted in this case, does not mean that injuries were caused by OSHA violations, nor do they justify the issuance of administrative warrant for gathering evidence of OSHA violations. Record keeping regulations as found in 29 CFR Part 1904 state that the recording of injuries on Log 300 does not mean that an employer is at fault or that an OSHA violation has occurred. This decision serves as guidance to employers to limit OSHA inspections to the complaint area. Unless the employer consents, a judicial warrant is required under the Fourth Amendment. If OSHA wishes to expand its search under information procured during initial inspection, the employer should seek legal counsel to limit the inspection as available under the current law.Walk-Through: Do not allow the inspector to veer in a direction not agreed in the scope at the opening conference! The compliance officer will observe safety, health conditions, and practices. When compliance officer finds a violation in open view, called the “plain view exception,” the scope of inspection now incorporates the plain view observation. The employer may shut down the area of the shop where the inspector will walk-through. The compliance officer may wish to interview employees to get their opinion of the accident at the workplace. Closing Conference: At the conclusion of the inspection, the compliance officer conducts a closing conference with the employer. The compliance officer gives the employer and all other parties involved a copy of Employer Rights and Responsibilities Following an OSHA Inspection for their review and discussion. The compliance officer discusses with the employer all unsafe or unhealthy conditions observed during the inspection and indicates all apparent violations for which he or she may issue or recommend a citation and a proposed penalty. The compliance officer will inform the employer of appeal rights.The office will request documents related to the inspection be mailed to OSHA in a specified time. Discuss the documents prior to submission with your counsel. At times, documents may be held back for reasons of privacy or relevance. CITATIONS & PENALTIES?Citations: OSHA citations inform the employer and employees of the regulations and standards alleged to have been violated and note the proposed length of time set to correct alleged violations. The employer must post a copy of each citation at or near the place a violation occurred for 3 days or until the violation is abated, whichever is longer. Certain notable violations for general industry in California for 2010-2016 can be found at https://www.dir.ca.gov/dosh/citation.htmlSam Celly of Celly Services, Inc. has been helping automobile dealers comply with EPA and OSHA regulations since 1987. Sam received his BE (1984) and MS (1986) in Chemical Engineering, followed by a J.D. from Southwestern University School of Law (1997). His newsletters can be accessed at www.epaoshablog.com. Your comments/questions are always welcome. Please send them to sam@cellyservices.com.3737 Birch St., Suite 220 Newport Beach, CA 92660WE ARE HERE FOR YOU.SUPPORT TEAM:— Answers support calls 24/7— Chats and shares screensduring business hoursACCOUNT EXECUTIVES:— Regularly check in with yourdealership— Work with you to minimizeerrors and penaltiesRESPONSE TEAM:— Provides short-term stangsupport as requested— Works at your dealershipon your deals AUDIT TEAM:— Audits each deal for accuracyand compliance— Scans deals for easy accessin DMVdesk— Sends audited bundles to DMVFULFILLMENT CENTER:— Sends plates, registration andstickers directly to your customers— Checks each shipment foraccuracyVITU INTERSTATE TEAM:— National title & registration takescare of your out-of-state buyersAT THE TIME OF SALE:— Run inquiries (KSR, NMVTISand more)— Create and print Temp Tagsand Reports of Sale— Oer customers free vehicleregistration renewal reminderswith DriverAFTER THE VEHICLE IS SOLD:— Finalize and submit eFiletransactions— Prepare and mail bundles toVitu for auditing— Send errors to SPU forprocessingWith a single screen and no tabbling, eFiling your deals is a breezeOur Account Executives never forget youLocal, California-based experts answer your questions quicklyDMVdesk does this all with easeAT YOUR DEALERSHIPAT VITUVisit dmvdesk.com or call 877-368-3375to learn more and schedule a demo.orange countyNext >