Inland Revenue launches construction industry campaign

Inland Revenue launches construction industry campaign

  • Inland Revenue targets the construction industry
  • The unfair tax treatment of ACC lump sum payments
  • The latest OECD data on carbon pricing

Transcript

This week, Inland Revenue launches a construction industry education campaign, an odd case highlights the continuing unfair tax treatment of lump sum payments, the OECD data around the use of taxes on carbon.

On Tuesday, Inland Revenue launched an education campaign for the construction industry. As its press release to tax agents indicated, “The purpose of the campaign is to engage with those in the construction industry, to ensure they’re getting it right from the start and support them in understanding their tax obligations if they undertake cash transactions.

The release goes on “Our customer research indicates that people are more likely to engage in hidden economy activity e.g., cash jobs, in an environment of economic uncertainty such as the current Covid-19 environment. We want to reduce the risk of this through awareness, education and compliance.”

And what it proposes to do is place Inland Revenue ads around building sites and hardware stores, together with online ads. Now, as part of this, Inland Revenue has put together a website called Rebuild NZ, and it’s to highlight to those in the construction industry how they can ensure they meet their tax obligations as well as doing their bit to help rebuild New Zealand.

Now, this is a useful initiative from Inland Revenue. They do these campaigns regularly. This one actually is quite interesting in that it is tackling the question of cash, jobs and cashies, but it’s not too heavy handed in its approach. Its website’s heading is “Cashies won’t rebuild our country”. So it’s playing on emotional strings. And this is actually quite standard practice now. You notice a play on what’s the consequences of not contributing to the tax take. The website declares every “undeclared cash job hurts our economy and the greater New Zealand.” So it’s really pulling the emotional triggers.

A couple of things of note on that. The website wisely, in my view, points out it’s OK to do cashies. You just need to declare them on your annual tax return. What Inland Revenue is saying is that per se, these aren’t illegal, but they become problematic if you don’t declare the revenue from them.

There will be some persons who, for whatever reason, want to be paid cash. And you can draw your own conclusions as to why they might want that. But if they are following the rules, make the necessary declarations then Inland Revenue is unconcerned, relatively speaking.

The other thing the website highlights here is, and I quote, “Can cash jobs really be tracked”? And it underlines this absolutely, giving the following example.

If two tradies work together, one declares a job, the other doesn’t. They can be dobbed in without realising it. If we audit one person, it might indicate another business or contractor that needs to be audited. Also, there’s always a chance of a random audit. We can see when tradies buy supplies such as paint, carpet or timber without a corresponding declared job. We can also access information held by other government departments, banks, loyalty cards, casinos and many other organisations to make sure all income is being declared.

Interesting reference to casinos in there, because clearly casinos are a place where cash is handy for gambling. And if you’ve read many tax cases down the years you’ll know an excuse for unexplained income is often, “Oh, I got lucky on the horses or down at a casino.”

So what they’re saying is it’s never too late to do the right thing, come forward, make voluntary disclosures, or if you wish, report tax or tax evasion or tax fraud anonymously.

As I said, we’ve seen a number of these campaigns before.  As Inland Revenue works through the final part of its Business Transformation programme and gets fully back up to speed we’ll see more and more resources deployed into taxing the hidden economy. The estimate is that it could be worth a billion dollars a year in undeclared GST and income tax.

ACC lump sum tax unfairness

Moving on. A case before the Taxation Review Authority, the tax equivalent of the District Court, caught my eye the other day. A taxpayer had commenced challenge proceedings against the Commissioner of Inland Revenue contesting the tax treatment of a lump sum paid to her by ACC on 9th November 2017. The payment was for weekly compensation due to her for the period from the date of her injury on 22nd April 2014 to 17th September 2017.

The taxpayer contended that the payment should have been treated for tax purposes as having been derived on an accruals basis and spread over the income years to which the payment related, rather than on a cash basis as assessed by the Commissioner.

As you can see, although she received over three years compensation in one sum, Inland Revenue treated it as income for the one year, even though it actually related to nearly three years, and taxed it at the relevant rate. And because of the way the tax system applied, a large chunk of that lump sum would have been taxed at 33%, when in fact probably it would have been taxed at lower rates had it been received when it should have been.

It’s not the first time I’ve seen this. It’s actually something I have raised directly with then Minister of Revenue Peter Dunne almost 10 years ago. It’s a well-known problem of the tax system, that whenever ACC denies a claim or is slow paying out, often the recipients lose out on the tax side of it, because when they finally get the correct amount of compensation, it’s paid as a lump sum and taxed accordingly.

The taxpayer in this case understandably outraged, then tried to take a case through the Taxation Review Authority. And in response, Inland Revenue – the Commissioner –  applied for an order striking it out as there was no cause of action as it was clearly untenable and could not succeed. And the TRA agreed there was no tenable prospect of success.

But that doesn’t get past the issue that the taxpayer had a very fair point, and it’s something, as I said, I’ve seen before. And it is frustrating that this continues to happen, and Inland Revenue and  successive Ministers of Revenue are inclined to do nothing about it.

In the interests of equity and fairness, this is an issue that should be addressed. By the way, the lump sum taxation of redundancy payments should also be addressed for the same reasons: a taxpayer may normally have their earnings taxed at 17.5%, but instead, when a lump sum, the tax system will tax it at 33%. And now with an increase in the tax rate to 39%, there is a likelihood that an even higher rate of tax – more than double in fact – could apply to a lump sum payment.

So addressing this is well overdue in my mind. But it’s funny, there’s a lot of stuff goes on in the tax world. But basic stuff like this which affects ordinary people, seems to just get left on the “Can’t be bothered” or “Too hard” piles.

Tax threshholds

And interestingly, yesterday an article came out in Stuff, which ties into this.  It pointed out how tax rates for those middle-income earners are too high relative to their income because the thresholds have not been adjusted since April 2008.

As Geof Nightingale of PWC and the Tax Working Group pointed out, most attention needs to be paid to the tax rate applicable to middle income earner:

“I think our harshest tax rate isn’t at 39% or 33%. It’s 30%, which cuts in at 48,000 dollars. That’s below the median wage. That jump from 17.5% to 30% in the dollar is a steep one. It seems tough to be hit with that tax rate when you’re earning below the median income”.

I agreed with that, as did Robyn Walker, a partner at Deloitte.

And we also gave examples that if thresholds had been raised in line with wage inflation, the threshold at which 33% kicks in, which is currently $70,000, would probably be nearer to $100,000. And the $48,000-dollar threshold, when it rises to  30%, would be about $67,000.

So the thresholds are now well out of whack. But again, governments of both hues seem inclined to not do much about it or, kick it down the road and pretend when they do something, it’s a tax cut. Something I think they’ve been allowed to get away with for too long.

And that’s why Simon Bridges has put in this private member’s bill to change that. It will be interesting to see what exactly happens to it. You can bet that politics will come into play and what is actually quite a sensible measure will probably be stifled.

Taxes on carbon

And finally, yesterday, 22nd April was Earth Day. And obviously there were a number of events in recognition of that event.  As part of the run up to Earth Day, the OECD released a brochure talking about effective carbon tax rates and how the 44 OECD and G20 countries price carbon emissions from energy use.

The OECD points out that carbon pricing is an effective decarbonisation policy because it makes low and zero carbon energy more competitive compared to high carbon alternatives by pricing carbon emissions properly. And it highlights what’s happened in the UK’s electricity sector, which used to be primarily coal and gas fired. The UK has increased effective carbon rates in that sector from seven euros per tonne of CO2 to more than 36 euros per tonne between 2012 and 2018. As a result, emissions in the electricity sector fell by 73% over that time.

And so what the OECD is saying is we should be looking at emission permit prices, carbon tax, or as we do here, an emissions trading scheme and fuel excise taxes. Fuel excise taxes always come with a caveat in that they are very regressive for low-income earners. One of the biggest problems we have with our transport policy here is the fuel taxes will hit low-income earners quite hard, particularly when we haven’t yet developed sufficient alternatives in public transport to enable alternatives

The OECD report wasn’t particularly complimentary about how the top 44 countries have been doing. It notes that three countries, Switzerland, Luxembourg and Norway, have reached a carbon pricing score rated on 60 euros per ton, which is the price expected by 2030 to be needed for carbon decarbonisation. Those three countries are close to 70% on that. And that’s mainly because of fuel taxes on the road sector.

But elsewhere, progress is patchy. Brazil and India are right down at one end of the scale. The USA is at 22%. New Zealand sits roughly just below the average at 33%.

There’s a lot of work to do and as we know, we’re now starting to get into the debate led by the Climate Change Commission as to how we deal with this matter. Tax is going to play a part in that.

As I said, fuel taxes are a problem for until we develop adequate alternative transport policies, public transport. Building more roads doesn’t help because that actually increases emissions. But the infrastructure deficit New Zealand has needs to be addressed and, tax will play a part in this.

As I’ve mentioned before, I think fringe benefit tax on high emission vehicles, as they do in the UK and Ireland, is something that we should be looking at. But I also feel very strongly that any taxes raised by this should be recycled back into ameliorating the impact for those who cannot choose alternatives to using their car.

Well, that’s it for today. Next week, I’ll be joined by John Cantin, a tax partner at KPMG who made some very interesting observations about the tax policy process and implications of the recent property tax proposals. We’ll be discussing this and the implications for the Generic Tax Policy Process.

I’m Terry Baucher and you can find this podcast on my website www.baucher.tax or wherever you get your podcasts. Thank you for listening and please send me your feedback and tell your friends and clients. Until next week Ka kite āno!

Cryptoassets under the spotlight

Cryptoassets under the spotlight

  • Cryptoassets under the spotlight
  • 10 years of compulsory zero rating for land transactions
  • A warning for trustees moving to Australia.

Transcript

New Zealand houses aren’t the only asset class that has exploded in value over the past 12 months. A report by the Secretary General of the OECD to the G20 finance ministers and central bank governors in Italy earlier this month noted that since he last reported to them in February 2021, the overall market capitalisation of virtual currencies has gone from just over US$1 tln to US$1.8 tln.

Now, quite apart from that near 80% increase, the growth has been almost five-fold since September 2020, when the market capitalisation was US$354 billion.

There are two things to note about this fantastic growth in value.  Firstly it is going to attract keen interest from the tax authorities who will want their cut of the gains that have arisen. And of course, the tax authorities are still struggling to keep up with the pace of change in this sector. And Inland Revenue is no different from the rest.

There are some rulings in preparation at Inland Revenue including an updated release on how it views the treatment of cryptoassets. But its general position remains that cryptoassets will be taxable, with rare exceptions on the basis that rather akin to gold bullion, the value can only ever be released by sale, so therefore they must have been acquired with a purpose or intent of sale.

The thing is though, the whole cryptoassets sector is rapidly becoming ever more complex and new instruments are being developed, which point to Inland Revenue’s argument as not necessarily being sustainable. So that’s one point that people must be noting when preparing their tax returns for the year ended 31 March 2021. Now I’m sure we will see people coming forward who have substantial cryptoassets gains and are wishing to make the right tax declaration.

But the other matter, which is of concern to tax authorities, is trying to keep track of all of this. As is well known, the OECD has developed in recent years the Common Reporting Standards on the Automatic Exchange of Information. And what the Secretary General for the OECD said in his tax report to the G20 finance ministers and Reserve Bank governors, is that the OECD is designing a “tax reporting and exchange framework that will address the tax compliance risks associated with the emergence of cryptoassets and reflecting the crucial role the crypto exchanges play as intermediaries in the cryptoassets market.”

Now, the proposal is that basically they want to bring cryptoassets into the common reporting standards and in exchange for information. So that’s going to be quite complicated. One of the attractions of cryptoassets is they are supposedly off the grid or under the radar of the tax authorities, and, how shall we describe it, that the reporting requirements are a little bit more relaxed.

Anyway, the OECD is preparing detailed technical proposals on this, on a new tax reporting framework. And it is intending to deliver a proposal to the G20 later this year. As usual, we’ll bring you news on that when they when it happens.

After ten years, there is still confusion

Moving on, it is 10 years since compulsory zero rating of land transactions was introduced. From 1st of April 2011 most sales of land and buildings between GST registered persons became zero rated for GST purposes under what we now call compulsory zero rating provisions. If these apply, then the land transaction must be zero rated.

Now the provisions were introduced to prevent what was seen as a trend towards “Phoenix fraud”, whereby a vendor did not pay output tax on the sale of property to Inland Revenue but the purchaser claimed a GST refund. The suggestions were that the annual loss in GST was in the tens of millions of dollars.

Now, it’s important to note that this is between GST registered persons and what it did was fundamentally shifted the GST risk on transactions involving land buildings from Inland Revenue to the parties involved. And as an excellent little report on the matter from PWC points out, that wasn’t always fully appreciated by parties to transactions, particularly those who were seeking to claim an import tax deduction on the purchase.

After 10 years these rules should be relatively well known now. However, there’s still quite a lot of issues emerging on that. And I regularly encounter the issue where a GST registered purchaser has bought land from what they understood to be an unregistered person, only to find out afterwards that the vendor either is or should have been GST registered. Now that often comes up when they file a GST return and claim the input tax credit. Now, the result is they don’t get any input tax credit and that purchaser is understandably very upset. The last such case I handled the vendor finished up paying almost $400,000 as a consequence of getting that GST status wrong.

And it seems surprising this should be happening because the standard sale and purchase agreement does have specific provisions on the whole schedule declaring the GST status of the parties involved. I mean, one of the risks is that the GST position of one party depends on the GST profile or information of the other party. So it’s not often that that level of tax detail is required in tax transactions, but they are for compulsory zero rated land transactions.

The report from PWC has useful little tips for vendors and purchases. But the key point it makes is parties have got to take extra care with this. They’ve got to make sure that the GST status of both parties is absolutely clear and understood at the time the agreement was entered into. Otherwise subsequently, it gets very messy and expensive and the only people who win are lawyers and accountants with fees, trying to sort out the mess. Inland Revenue is quite happy about all of this because, as I said earlier, it has shifted the risk.

So generally speaking, if something goes wrong, it gets its cut and leaves it to the other parties in the transaction to sort themselves out. So again, pay attention if you’re involved in the purchase of land and buildings. It’s a compulsory zero rated transaction for GST purposes. Pay attention and make sure all the Is are dotted and the Ts are crossed.

A warning for trustees

And finally, just another reminder popped up with a new client coming to me this week, with a common issue, and that is the status of trustees who move to Australia.

Now as the Australian tax legislation for income tax purposes, deems a trust to be resident in Australia, if any trustee is a tax resident of Australia. So you could have a trust with seven, nine, 11, whatever number of trustees. But if one of those trustees is resident in Australia, then the trust is deemed to be resident in Australia and the consequences, particularly around capital gains tax, become potentially very severe.

There’s a slight anomaly in this position because often individuals that move from New Zealand to Australia qualify as what the Australian tax legislation calls a temporary resident.

And what that means is rather like our own transitional residence exemption. Non-Australian sourced income and gains are not taxable in Australia, but trusts are not covered, or companies are not covered by that exemption. So there is the situation where an individual who receives a distribution from a New Zealand trust is not going to be taxable on that in Australia, but if he is a trustee of that trust, making the distribution to him or her, then the trust is now within the Australian tax net.

So this new client is a reminder for anyone moving to Australia and they are either a trustee or have a power of appointment over trustees, then they need to resign as the trustee and revoke/transfer that power to another person who is not an Australian tax resident.

Given the sheer number of trusts we have in New Zealand, approximately half a million at last estimate, this is going to be a quite common scenario. So even if it is just a family trust holding a former residential family home in New Zealand, they could well be landed with a whole heap of Australian tax issues.

So anyone moving to Australia should take advice on the tax implications of you doing so and make full disclosures to your advisors. It is like the mess ups we see with the compulsory GST rating and land transactions. It’s astonishing how people are rather casual when explaining their circumstances to their advisers and often with very expensive consequences.

Well, that’s it for today. I’m Terry Baucher and you can find this podcast on my website www.baucher.tax or wherever you get your podcasts. Thank you for listening and please  send me your feedback and tell your friends and clients until next week, Ka kite āno.

Small Businesses and tax compliance, PAYE for employees of overseas companies

Small Businesses and tax compliance, PAYE for employees of overseas companies

  • Small Businesses and tax compliance, PAYE for employees of overseas companies
  • Managing fringe benefit tax
  • A global minimum corporate tax rate?

Transcript

Friday was Small Business Day. If you spent money with a participating small business and posted your interchange on social media, you and the business could have won a share of $200,000 dollars. Now, this is part of an initiative underlining the importance of small businesses in the New Zealand economy.

MBIE defines a small business as one with fewer than 20 employees. And according to Stats New Zealand, there are approximately 530,000 small businesses in New Zealand meeting that definition. They represent 97% of all firms, account for 28% of employment and just over a quarter of New Zealand’s GDP.

So they’re very important to the economy, but most importantly, also for the community. When small businesses move out, the community suffers. So this sort of initiative and the work we were doing during my time with the Small Business Council is important for the economy.

However, when it comes to the tax system there’s actually very few concessions for small businesses. That is part of a deliberate policy, which generally I and most tax experts support, of minimising special exemptions and in doing so, focusing on the basics. And by minimising removing special exemptions, you eliminate the opportunities for people to try and rort the system.

But that comes at a cost for small businesses of greater compliance costs. Compliance costs will always fall heavily on small businesses because they are generally quite under-resourced to deal with this matter.

Now as I said currently our tax system generally makes no concessions for small businesses. However, there is one such example which does apply, and that is the shareholder-employee regime. Under this regime a shareholder who is also an employee of a company can instead of having their salary taxed through pay as you earn, opt to pay provisional tax. Their taxable income can then be determined after the end of the tax year.

It’s a very flexible regime, but it doesn’t always fit well with the general scheme of the Income Tax Act. And I think Inland Revenue may be thinking in terms of such businesses should actually be in the look through company regime. The problem is these special regimes add complexity.

The tax loss carryback regime, which is temporarily in place for the 2020 and 2021 income years, proved unworkable for shareholder employees. They’d already taken profits out of the business by way of a salary. So if the company had a loss in either of those later years and tried carrying it back, it had no income to offset against the loss. So, it was of no use to shareholders employees.

When other tax practitioners and I were discussing a permanent iteration of the current loss carryback regime with Inland Revenue policy a huge stumbling block was the question of the treatment of shareholder employees. In fact, it proved unworkable in the end. And last month the Minister of Revenue revealed a permanent iteration of the scheme is not going to be implemented.

In my view one of the side effects of not having specific small business regimes, is that Inland Revenue policymakers don’t pay enough attention to what’s going on in the small business sector, and that means compliance costs creep up for the sector as issues are not addressed. And in the last week, we’ve had a couple of good examples of how this has played out.

Covid-19 has revealed, a number of things that should have been addressed in relation to employer employee relationships, but for whatever reason had been parked as there was always something more interesting to work on. These strains have started to come through recently.

There was a story in the Herald (paywalled) about a very common thing, Kiwis coming back to New Zealand, but continuing to work for overseas based employers. And what’s happening is that a number of these are potentially facing double taxation, hopefully temporarily, and they understandably are confused about how much they own to which government.

One key concern is if an employee of an overseas employer is in New Zealand for more than 183 days, then technically the employer will need to start accounting for pay as you earn. However, in the meantime, that overseas jurisdiction may still be applying its equivalent of pay as you earn to the employee’s earnings. So there’s a risk of double taxation risk.

And one of the other problems is with foreign tax credits. Technically, under double tax agreements employment is taxable only in the jurisdiction in which it’s being exercised. So as the Herald article pointed out, in a worst case scenario, what can happen is that someone working in New Zealand for an overseas employer may have earned $100,000 dollars and paid UK pay as you earn, but won’t get any credit for it in New Zealand. Inland Revenue’s view is “Well, you’ve earned $100,000. This is the tax bill, pay it.” Meantime, the problem that particular employee faces is that he or she have to then go and get the overpaid UK tax refunded. And of course, that can take some time.

And it may also involve getting assistance through what we call the mutual agreement procedures between Inland Revenue here and the UK’s HM Revenue & Customs.  All this takes a lot of time and a lot of stress. It’s a very good example of how the system is evolved, where it really isn’t terribly flexible, and issues arise. One answer is to put people into the Provisional tax regime. Another one is for such employees of overseas companies to register themselves for pay as you earn or what they call an IR56 taxpayer.

Now just to clarify, we’re assuming that the employees of the overseas company, is just an employee, and we’re not dealing with the issues of that employee having sufficient authority to create what we call a permanent establishment, which is a whole other raft of issues, but are not relevant to this particular discussion.

Issues are starting to emerge where the IRS is expecting the US employer to deduct the US equivalent of pay as you earn. Meanwhile Inland Revenue here wants its cut and although the double tax agreement will give most taxing rights to New Zealand the IRS is very cumbersome in moving to say to the US employer, “Oh, yes, that’s now foreign sourced income so you no longer need to deduct tax.”

And then there’s the other issue I mentioned that the overseas company, could be treated as an employer and required to deduct PAYE in New Zealand. Now, fortunately, in that respect, Inland Revenue has a draft operational statement, which was released for consultation last year which deals with this issue of non-resident employers’ obligations to deduct pay as you earn, pay FBT and deduct employer superannuation contribution tax. The deadline for comments closed on it on 1st September so we ought to be seeing it fairly soon in final form.

And basically, Inland Revenue is saying an overseas employer isn’t going to need to apply PAYE so long as the employee’s presence does not create a permanent establishment or as the operational statement has it, “a sufficient presence.” So that’s a good solution. But I think this illustrates the problems with small businesses overseas and here of dealing with issues around tax systems that weren’t designed with such matters and are slow to respond.

And that leads on to a second related point, the question of fringe benefit tax and the new 39% tax rate, which came into effect on 1st April. As a consequence of the change in the tax rate, a new flat rate of FBT of 63.93% applies to non-cash employee benefits such as discounted goods and services and private use of company cars. But that only applies in in reality to employees earning more than $180,000, which is only 2% of earners.

But the FBT system expects employers to pay using a single rate which prior to 1st April was 49.25%. And so the increase to 63.93% represents a substantial burden. Now, it’s possible to work around that and not use the flat FBT rate by filing quarterly FBT returns and calculating FBT on an attributed basis, i.e. for each employee.

So, yes, that’s a solution, but it leads back to my point at the start of this podcast, it adds to complexity of the tax system and also increases the burden of compliance with small businesses. So I think the point has been reached in our system that going forward, Inland Revenue really should have a hard think about the fringe benefit tax compliance costs for small businesses.

Leaving aside the separate issue of how well FBT is being complied with, particularly in relation to work related vehicle, it does involve a fair amount of compliance for small businesses. The FBT regime dates from the mid-80s and I think it’s time for a rethink. In the 1980s it was probably a sensible approach that the employer paid FBT. Maybe now with better procedures in place, what should happen is that the employer calculates the value of the fringe benefit and that amount is then included as part of an employee’s salary and taxed at the relevant rate. This would immediately deal with the issue of applying this new 63.93%rate.

But that’s something that needs to be considered, perhaps as part a whole package of looking at compliance for small businesses. And I understand there is something in the works on that which we will be watching with great interest and report back on when we hear something in due course.

And finally this week, we’ve talked in the past about the international tax regime striving to try with the digital economy and each tax jurisdiction trying to find an appropriate level of taxation relative to a company’s economic activity in a country. The focus is on the GAFA, as they call Google, Apple, Facebook and Amazon.

Here in New Zealand these companies pay very little tax. Facebook does not publish financial statements in New Zealand, and Google’s accounts to December 2019 show that its revenue in New Zealand was  $36.2 million. And it finished up, paying $3.6 million in income tax. That was actually an increase in from the 2018 year, where it paid around $400,000. But Google’s revenue from New Zealand is considerably more than $36 million.

And what’s happening here is replicated all around the world. So the OECD has been looking at this in conjunction with the G20 group of nations. This is part of a shift to try and stop the aggressive use of tax havens to minimise multinationals’ corporate tax bills. And this past week after a meeting of G20 finance ministers there appears to have been a breakthrough in that they are now exploring the equivalent of a global minimum tax on corporate profits.

What’s encouraging about this is that the US Treasury Secretary Janet Yellen, initiated the proposal, and this is a rapid, significant change from the Trump administration. There will be pushback on this, obviously, because certain jurisdictions and Ireland has been mentioned as one who already have a fairly low tax rate, concerned that their current 12.5% corporate tax rate may rise.

And obviously, tax havens will be looking at this with some unease. But my personal view is that the days of the tax havens are numbered because of the double impact of the Global Financial Crisis and Covid-19 anyway. It remains to be seen how well this will develop, but it is an encouraging sign. It might not actually make a great deal of difference to the New Zealand Government’s books, but it will certainly be a step forward in the right direction. As always, we will bring you developments as they happen.

Well that’s it for today, I’m Terry Baucher and you can find this podcast on my website www.baucher.tax or wherever you get your podcasts. Thank you for listening and please send me your feedback and tell your friends and clients. Until next week Ka kite ano!