This document provides a summary of a presentation on recent and proposed tax changes. It was presented by Plante Moran's Tax Department and covered various federal tax topics including: - President Obama's tax policy proposals for individuals and businesses. - Recent legislation including provisions of the Worker, Homeownership, and Business Assistance Act of 2009. - Expiring tax provisions at the end of 2009. - Health care reform proposals being considered and their tax implications. - The current state of estate and gift taxes and proposals to reform them. - Tax issues related to distressed companies including alternative minimum tax, state taxes, payroll taxes, and cancellation of debt income. - Energy tax credits and

1. PREPARE FOR THE UPSWING:
>> WHAT'S NEW ON THE
TAX FRONT?
TOPICS4THETIMES
>> PRESENTED BY: PLANTE & MORAN’S TAX DEPARTMENT
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2. TODAY’S PRESENTERS
KURT PIWKO JIM MANNING
586.416.4948 616.643.4054
KURT.PIWKO@PLANTEMORAN.COM JIM.MANNING@PLANTEMORAN.COM
CURTIS RUPPAL JERRY JONCKHEERE
616.643.4069 616.643.4044
CURTIS.RUPPAL@PLANTEMORAN.COM JEROME.JONCKHEERE@PLANTEMORAN.COM

3. PREPARE FOR THE UPSWING:
>> FEDERAL TAX
TOPICS4THETIMES
>> PRESENTED BY: KURT PIWKO
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4. PRESIDENT OBAMA’S TAX POLICY
2009 2011 – Current Law 2011 – Obama
Ordinary Income Tax Rates
10% 15% 10%
15% 15% 15%
25% 28% 25%
28% 31% 28%
33% 36% 36%
35% 39.6% 39.6%
Capital Gain Tax Rates
0%/15% 8%/18% & 10%/20% 0%/15%/20%
Qualified Dividend Tax Rates
0%/15% Up to 39.6%
Up to 39 6% 0%/15%/20%

5. PRESIDENT OBAMA’S TAX POLICY
• INDIVIDUAL
– Restoration of the exemption and itemized deduction phase-
outs for high-income individuals
– Limit the tax rate at which itemized deductions reduce tax
liability to 28%
– Make the Making-Work-Pay credit permanent
– Supports 4% payroll tax surcharge on high income individuals
high-income
• BUSINESS
– Repeal LIFO method of accounting for inventory
– Make the research credit permanent
– Tax carried interests as ordinary income
– International tax reform

6. OTHER TAX DEVELOPMENTS
• WORKER, HOMEOWNERSHIP, AND BUSINESS ASSISTANCE ACT OF
2009 (SIGNED NOVEMBER 6, 2009)
– Extends unemployment benefits by 14 weeks (20 in some
states)
– Extends and expands first-time homebuyer credit
• Extended through April 30, 2010 and includes a 60 day “grace
period” after April 30 as long as a purchase agreement is in place
• I
Increases AGI limitations to $145k ( i l ) and $245k (j i t)
li it ti t (single) d (joint)
• Creates $6,500 credit for individuals who owned and lived in their
principle residence for 5 of the past 8 years
– Creates election to carryback a 2008 or 2009 net operating loss
3, 4 or 5 years
• Applies to both corporations and individuals
• Election available for only one year, not both

7. OTHER TAX DEVELOPMENTS
• THE FOLLOWING PROVISIONS ARE SOME OF THE ITEMS SCHEDULED TO
EXPIRE A THE END O 2009
P R AT D OF
– Individual
Deduction for state and local sales taxes
Tuition and fees deduction
Educator expense deduction
Direct contribution of IRAs to charity
Sales tax deduction for motor vehicle purchases
Increased AMT exemptions
I d ti
Availability of personal credits against AMT
– Business
Research credit
15 year amortization of qualified leasehold improvements
50% bonus depreciation
Increased §179 expense limitations
• LEGISLATION ON OTHER ISSUES IS BEING DEBATED IN CONGRESS

8. HEALTH CARE REFORM PROPOSALS
House Leadership – Affordable Senate Finance Committee –
Health Care for America Act
Health Care for America Act America s Healthy Future Act of
America’s Healthy Future Act of
(H.R. 3962) – 10/29/2009 2009 – 10/13/09
High‐income individual 5.4% surcharge on individuals n/a
tax surcharge with AGI >$500k (or families
>$1M), effective 1/1/11
$
Excise tax on 2.5% of adjusted income above $750 per adult, phased‐in beginning
individuals without minimum level, up to minimum in 2014
q
qualifying coverage
y g g cost of plan, effective 1/1/13
p , / /
Employer fees and 8% of payroll fee for employers Fee for each employee not covered
taxes not providing minimum by plan, effective 1/1/13 (equal to the
coverage and subsidies, average tax credit received by employees
effective 1/1/13
effective 1/1/13 in the U.S. multiplied by # of employees
in the U S multiplied by # of employees
not covered)
Excise tax on insurers of n/a 40% of value of plan exceeding
employer‐sponsored defined minimums, phased‐in
“luxury” plans
luxury plans beginning in 2013
beginning in 2013

9. HEALTH CARE REFORM PROPOSALS
House Leadership – Senate Finance Committee –
Affordable Health Care for America’s Healthy Future Act of 2009
America Act (H.R. 3962) – – 10/13/09
10/29/2009
Non‐qualified HSA Increases penalty from 10% Same as House
distributions to 20%, effective 1/1/11
to 20% effecti e 1/1/11
Reimbursements from Prevent OTC drugs from Same as House
HSA, FSA, HRA or Archer, being reimbursed tax‐free,
accounts effective 1/1/11
Medical expense n/a Increase 7.5% of AGI floor to 10% with
itemized deductions exemption for individuals >65 years
FSA contributions Limits contributions to Same as House
$2,500, effective 1/1/13
Medical industry 2.5% tax on first sale of a Impose fees over 10 years: $2.3B on RX
taxes/fees medical device, effective producers, $4B on medical device
1/1/13 producers, $6.7B on health insurers
producers $6 7B on health insurers

10. ESTATE & GIFT TAX
CURRENT STATE OF ESTATE AND GIFT TAXES
Year Basis of Estate & Estate & Gift Tax Gift Tax
Inherited GST* GST* Rate Exemption Rate
Assets Exemption
2008 Fair market $2,000,000 45% $1,000,000 45%
value
2009 Fair market $3,500,000 45% $1,000,000 45%
value
2010 Carryover Repealed Repealed $1,000,000 35%
2011 Fair market $1,000,000 55% $1,000,000 55%
value
* GST = GENERATION SKIPPING TAX

11. ESTATE & GIFT TAX
PROPOSED ESTATE TAX REFORMS
Bills Introduced H.R. 436 H.R. 498 S.722 H.R. 2032 Obama
in 2009 (Pomeroy) (Mitchell) (Baucus) (McDermott) Administration
January 9 January 14 March 26 April 22
Estate Tax $3.5M, NOT indexed $5M, indexed , phased $3.5M, indexed $2M, indexed $3.5M, indexed
Exemption in from 2010‐2015
Estate Tax Rate 45%, with a surtax on $25M or less, Capital 45% $2M‐$5M, 45%; $5M‐ 45%
estates >$10M gains rate (CGR); >$25m, 10M, 50%; >$10M,
2X CGR ; indexed 55%; Indexed
Portability of No Yes Yes Yes No
Unused Exemption
by Surviving Spouse
Reunification of Yes Yes Yes Yes No
Estate and Gift Tax
Reinstate State No No No Yes n/a
Death Tax Credit
Death Tax Credit
Valuation Rules and Restrict valuation No Cap of $3.5M No Similar to HR 436,
Transfer Strategies discounts on minority on special use but not as broad;
interests and non‐ valuation minimum 10 year
business assets reduction term for GRATs
Stepped Up Basis Yes Yes Yes Yes Yes

12. TAX ISSUES FOR DISTRESSED COMPANIES
LOSS COMPANIES MIGHT STILL PAY TAX
• ALTERNATIVE MINIMUM TAX (AMT) LIABILITIES
– Regular taxable income can be offset 100% by regular NOLs
– Corporate AMT Income can be offset only 90% by AMT NOLs
• Effectively a 2% tax on AMT income
• STATE TAX LIABILITIES
– Corporate consolidated groups
• Taxes may be due on the income of profitable subsidiaries if
combined/consolidated state returns are not available/filed
• C ld apply t LLC groups if state d
Could l to t t does not di
t disregard single member
d i l b
LLCs
– State franchise or privilege taxes not based on income
• Gross receipts or margins tax (i.e., OH, MI, TX, etc.)
• Franchise or capital tax
• PAYROLL TAXES
– Never cease as long as employees exist

13. TAX ISSUES FOR DISTRESSED COMPANIES
PERSONAL LIABILITY FOR TAXES
• “RESPONSIBLE PERSONS” CAN BE HELD LIABLE FOR CERTAIN
FEDERAL PAYROLL AND EXCISE TAXES IF THEY “WILLFULLY” FAIL
TO PERFORM THE DUTY TO PAY
– This may include anyone who has responsibility over taxes or
cash payments
• MANY STATES IMPOSE PERSONAL LIABILITY ON CORPORATE
OFFICERS AND OTHERS
– This may include payroll taxes, sales tax, privilege taxes, or
income/franchise taxes
• EMPLOYEES AND OFFICERS MUST BE COGNIZANT OF THE
GOVERNMENT’S POSITION ON A “PREFERRED PAYMENT” LIST
WHEN CASH RUNS SHORT

14. TAX ISSUES FOR DISTRESSED COMPANIES
BAD DEBT DEDUCTIONS
• WHEN A BUSINESS TRADE RECEIVABLE BECOMES WHOLLY OR
PARTIALLY WORTHLESS, A TAXPAYER GENERALLY MAY WRITE IT
OFF TO OBTAIN AN ORDINARY DEDUCTION
• TO BE DEDUCTIBLE, A TRADE RECEIVABLE MUST BE SPECIFICALLY
WRITTEN-OFF ON THE TAXPAYER'S BOOKS VERSUS BEING
RESERVED FOR IN AN ALLOWANCE ACCOUNT
• BAD DEBT DETERMINATION IS NOT REQUIRED UNTIL YEAR-END
Q
BUT MID-YEAR DETERMINATIONS CAN BE TAKEN INTO ACCOUNT
WHEN DETERMINING QUARTERLY ESTIMATES

15. TAX ISSUES FOR DISTRESSED COMPANIES
BAD DEBT DEDUCTIONS (CONTINUED)
• RELEVANT FACTORS SUGGESTING DECREASE IN VALUE:
– Serious financial reverses of the debtor
– Insolvency
– Lack of assets
– Persistent refusals to pay
– Abandonment of the business
– Bankruptcy and receivership
– Security ( any)
y (if y)
– Expiration of the statute of limitations
• RELEVANT FACTORS SUGGESTING NO DECREASE IN VALUE:
– Creditors
Creditors’ failure to press for payment
– Creditors’ willingness to make further advances
– Availability of collateral or guarantees
– Debtors earning capacity
– Continued operations

16. TAX ISSUES FOR DISTRESSED COMPANIES
CANCELLATION OF DEBT (COD)
• COD INCOME IS GENERALLY TAXABLE
– Exclusions exist for bankrupt or insolvent taxpayers
– If COD is excluded from income, tax attributes must be reduced
(i.e., NOLs
(i e NOLs, credit carryforwards, asset basis, etc )
carryforwards basis etc.)
• BUSINESS COD INCOME RECOGNIZED IN 2009 AND 2010 CAN BE
DEFERRED AND RECOGNIZED IN TAXABLE INCOME OVER A FIVE
YEAR PERIOD BEGINNING IN 2014
– Applies to most types of COD income
– Election i
El ti is made at entity level and i d with th t return
d t tit l l d is due ith the tax t
– Partial and protective elections are available
– Partnerships have flexibility to make the election for each
partner’s allocable share of COD income

17. PREPARE FOR THE UPSWING:
>> ENERGY TAX
TOPICS4THETIMES
>> PRESENTED BY: JIM MANNING
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18. ENERGY CREDITS & INCENTIVES
• SEVERAL THINGS ARE DRIVING THIS MARKET
FASTER AND IN NEW DIRECTIONS:
– Cost – Opportunity to save dollars
– Environmental awareness/concerns
– Uncertainty around supply of nonrenewables
– Effect of green house gases
– Uncertainty around federal carbon p
y policyy
– RPS – Renewable Portfolio Standards in 28 States

19. ENERGY CREDITS & INCENTIVES
• SECTION 179D OR ENERGY EFFICIENT
COMMERCIAL BUILDING DEDUCTION OR EPACT
• SECTION 45 RENEWABLE ELECTRICITY
PRODUCTION CREDIT
• SECTION 48 ENERGY INVESTMENT CREDIT
• STATE & UTILITY INCENTIVES AND REBATES
• SECTION 25C & D RESIDENTIAL ENERGY
EFFICIENT PROPERTY CREDIT

20. SECTION 179D – ENERGY DEDUCTION
• ACCELERATED DEDUCTION INVESTMENTS IN
EECB PROPERTY
• MAXIMUM IS $1.80 PER SQ. FT. FOR:
– HVAC — $.60 cents
– Lighting — $.60 cents
– Building Envelope — $ 60 cents
$.60

21. SECTION 179D – ENERGY DEDUCTION
• REQUIRED ENERGY IMPROVEMENT IS 50% TO GET
FULL $1.80 OR 16 2/3% TO GET INDIVIDUAL
SYSTEMS
• OPPORTUNITY FOR A/E FIRMS DOING
GOVERNMENT WORK
• OPPORTUNITY FOR LIGHTING SYSTEMS
• EXTENDED THROUGH 2013

22. ENERGY CREDITS & INCENTIVES

23. SECTION 45
RENEWABLE ELECTRICITY PRODUCTION CREDIT (PTC)
• 10 YEAR CREDIT BASED ON ELECTRICITY PRODUCED:
– Wind
– Solar
– Closed and open loop biomass
– Geothermal
– Small irrigation power
– Municipal solid waste
– Hydropower
– Marine and hydrokinetic
– Energy must be sold to unrelated party
– Credits
C dit can b sold t i
be ld to investors
t

24. SECTION 48A
ENERGY INVESTMENT CREDIT (ITC)
• 10% CREDIT FOR INVESTMENTS IN:
– Geothermal
– Combined heat & power systems

25. SECTION 48A
ENERGY INVESTMENT CREDIT (ITC)
• 30% CREDIT FOR INVESTMENTS IN:
– Wind energy property
– Solar property
– Biomass
– Fuel cell property
– Other
O h renewable energy (see Section 45)
bl ( S i

26. SECTION 1603
CASH GRANT IN LIEU OF ITC
• GRANT CAN BE ELECTED IN LIEU OF ITC:
– Review depreciation and whether the client can
use the deduction
– The Grant is not taxable
– Same technologies that qualify for ITC qualify for
the grant

27. LIMITATIONS ON TAX CREDITS
• PASSIVE ACTIVITY LOSSES
– Limits deductions and incentives to only active
investors
– Posing significant financing hurdles for
developers
– Narrows investment to non-closely held
corporations

28. LIMITATIONS ON TAX CREDITS
• IN-SERVICE DATE
S
– Construction must start prior to December 31, 2010
– In-Service
In Service by January 1, 2012 2014
1 2012-2014
• FOR-PROFIT CORPORATIONS
P
– Eliminates governments, NFP, institutional, and
pension funds

29. LIMITATIONS ON TAX CREDITS

30. STATE & UTILITY INCENTIVES
• UTILITY INCENTIVES
– Standard (Prescriptive) incentives
– Custom incentives
– New building analysis
– Load response & utilization
• STATE INCENTIVES
– Grants
– Loans
– Credits

31. SECTION 25C
NON-BUSINESS ENERGY PROPERTY
• 30% CREDIT FOR INVESTMENTS IN ENERGY EFFICIENT
IMPROVEMENTS – MAX IS $1,500 FOR 2009 &
2010
– Building envelope – Windows, roof, doors
– Furnace systems
– Central air conditioners
– Water heaters
• CREDIT LAPSED IN 2008
• EXTENDED FOR PROPERTY PLACED IN SERVICE 2009
& 2010

32. SECTION 25D
RESIDENTIAL ENERGY EFFICIENT PROPERTY CREDIT
• 30% CREDIT FOR RESIDENTIAL INVESTMENTS IN:
– Solar
– Small wind energy property
– Fuel cell property
– Geothermal
• CAN INCLUDE INSTALLATION COSTS
• TAX CREDIT – NOT GRANT

33. SECTION 25D
RESIDENTIAL ENERGY EFFICIENT PROPERTY CREDIT
• EFFECTIVE FOR PROPERTY PLACED IN SERVICE
2009 – 2016
• $2,000 CAP WAS LIFTED IN FEBRUARY WHEN
EXTENDED
• CREDITS ARE LIMITED TO TAX AND DO CARRY
FORWARD

34. PREPARE FOR THE UPSWING:
>> STATE TAX
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>> PRESENTED BY: CURTIS RUPPAL
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35. ILLINOIS
• PARTNERSHIP INCOME MODIFICATIONS
– Guaranteed payment add-back and reasonable
compensation subtraction
p
• MANUFACTURER’S PURCHASE CREDIT
– Credit extended through August 30, 2014

36. MICHIGAN
• MICHIGAN BUSINESS TAX
– Planning opportunities abound
– Treasury Rules and Administrative Bulletins
• SINGLE BUSINESS TAX REFUND OPPORTUNITIES
– Kmart Michigan Property Services LLC – treatment of
Services,
federal disregarded entities
– TMW Enterprises, Inc. – application of casual
transaction to S corporations
• FUTURE TAX POLICY

37. OHIO
• COMMERCIAL ACTIVITIES TAX
– 0.26% tax rate fully phased-in
– New provisions: Penalty for pass through of tax; Joint and
several liability
– Ohio Grocers Association v. Levin – CAT is a tax on the
privilege of doing business
– Overstock.com, Inc. v. Levin – challenge to CAT economic
nexus standard dismissed on procedural grounds
• INDIVIDUAL INCOME TAX
– HB 318 – 2009 tax rate reduction in jeopardy?

38. MULTISTATE – STATE REACTIONS TO RECESSION
• BUSINESS/CORPORATE INCOME TAX
– Enact combined/unitary group reporting – MA, WV, WI; previously
MI MBT, OH CAT, TX Franchise (Margins) Tax
– Enact tax base add-backs for certain related party expenses
(types vary by state) – AR, DC, GA, CO, ND, OK, VA, WI, WV
– Economic nexus - via enacted law, regulation, or administrative
policy – ME MI, NH, NY, OH OR WI
ME, MI NH NY OH, OR,
– Sales Factor Apportionment
• Shift to move heavily weight sales factor - CO, PA
• Shif from origin sourcing to market sourcing f service
Shift f i i i k i for i
revenue – CA (2011), IL (2008), MI (2008), WI (2009)
– Suspend NOL carryforward utilization – CA

39. MULTISTATE – STATE REACTIONS TO RECESSION
• INCREASE SALES TAX RATE OR EXPAND TAX BASE
– Tax rate increases – CA, MA, NV
– Tax base expansion – CA, KY, ME, TN
– Also have see enactment of “Amazon” nexus for
internet sellers with certain types of relationships
yp p
with in-state independent companies
Enacted in NY (lead), NC, RI
Rejected in CA, HI
Proposed in CT, IL, MD, MN, TN

40. MULTISTATE – STATE REACTIONS TO RECESSION
• INCREASE UNEMPLOYMENT INSURANCE TAX WAGE BASE
AND RATES
– 2009 retroactive wage base increases – TN, WV
– 2010 wage base increases – AR IN, IA FL MT MO VT
AR, IN IA, FL, MT, MO,
– Anticipated 2010 rate increases (not connected to individual
employer experience history) – FL, HI, IA, KS
• FEDERAL LOANS FOR SUI TRUST FUND
– Borrowing can result in reduced FUTA credit for SUTA taxes paid
2009 – MI employers
2010 – possibly IN, MI, and SC
2011 – possibly AR, CA, IN, KY, MI, MO, NY, NY, NC, OH, PA, RI,
SC, d
SC and WI

41. MULTISTATE – STATE REACTIONS TO RECESSION
• INCREASE INDIVIDUAL INCOME TAX RATE
– Graduated income tax rate states have generally focused
on high-income brackets only
– Examples – NJ, NY, WI (NJ change estimated to increase
state revenues $1 Billion in fiscal year 2010)
– Also have see accele at o o state est ates
lso ave seen acceleration of estimates
For 2010, CA quarterly estimates are to be paid in as
follows:
1st qtr = 30% 2nd qtr = 40% 3rd qtr = 0% 4th qtr = 30%
t 30%; t 40%; t 0%; t
(that’s right, pay 70% of estimated liability by June)

42. MULTISTATE – STATE REACTIONS TO RECESSION
• ADMINISTRATIVE ENFORCEMENT
– Increase in nexus non-filer discovery initiatives
– Increase in quantity and aggressiveness of tax audits
• AMNESTY PROGRAMS
– Recently completed (2009)
AL, AZ, CT, DE, HI, LA, MD, NJ, VT
– On-going – ME, OR, VA
– Scheduled – PA
– Proposed – DC, IL, MI

43. PREPARE FOR THE UPSWING:
>> INTERNATIONAL TAX
TOPICS4THETIMES
>> PRESENTED BY: JERRY JONCKHEERE
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44. FOREIGN BANK ACCOUNT REPORTING
• IRS IS SERIOUS ABOUT REPORTING
– They took on UBS (the large Swiss bank)
– They took several aggressive tax cheats to court –
and won
– They set up a Voluntary Disclosure program to ferret
out violators
• LOOK FOR PENALTIES TO BE ASSESSED IN THE
FUTURE FOR NON-FILERS

45. TIER ONE ISSUES
• TRANSFER PRICING
– Actually *not* a Tier One Issue
–B A
But Automatic on all A di
i ll Audits
– The “30 Day Letter”
• WITHHOLDING ON PAYMENTS TO ALIENS
– Forms 1042

46. FORM 5471 REPORTING (AND PENALTIES)
• WINTER 2008: LATE 5471S WILL BE
SUBJECT TO AUTOMATIC PENALTIES
– Voluntary Disclosure ended 10/15
• IRS SEEMS SERIOUS ABOUT ASSESSING
PENALTIES
– Reasonable Cause is a high standard to prove
g p
to avoid penalties

47. MISTAKE CORRECTIONS
• REV PROC 2009-41
2009 41
– Allows taxpayers three years (+75 days) to
correct missed “check-the-box” elections
check the box
– As long as intent is clear in returns filed
– P b bl more difficult to get 9100 relief if
Probably diffi lt t t li f
intent is not clear (wrong or no returns filed)

48. TAX PLANNING IDEAS
• DISCS (DOMESTIC INTERNATIONAL SALES
CORPORATION)
– Still Viable – Obama has indicated he would
continue preferential qualified dividend rates
– Effective tax planning device for exporters

49. CROSSBORDER ISSUES
• CANADA
– Increased enforcement of Schedule 91s
The “t
Th “tax return t t ll C
t to tell Canada you d ’t owe
d don’t
them a tax return”
• UNITED STATES
– Form 1120F for foreign corporation operating
in the U.S.

50. “BUSINESS TAXES”
• GROWING TREND TOWARD TAXES NOT DEFINED IN
TREATIES
– Taxes on foreign companies with no permanent
establishments
– Gross taxes on business income
– NOT CREDITABLE for U.S. tax purposes

51. TRANSFER PRICING
• U S COMPANIES WITH TRANSACTIONS WITH
U.S.
RELATED FOREIGN COMPANIES MUST:
– Document how prices are determined
– Documentation must meet U.S. and foreign
standards for arm’s length documentation
arm s
– Increasing focus of U.S., Canadian, Mexican,
and foreign audits

52. DOTTING THE “I”S AND CROSSING THE “T”S
• IRS IS SCRUTINIZING RETURNS FOR
ATTACHMENTS AND FORMS
– Significant penalties are in statutes for non
non-
compliance
– Form 3520 & 3520-A for foreign trusts
3520 A
– Form 5713 for transactions or bids with countries
boycotting Israel
– Form 926 for cash or asset transfers overseas
– Dual Consolidated Loss Statements

53. U.S. – CANADA TREATY -- FIFTH PROTOCOL
• U S – CANADA FIFTH PROTOCOL TAKES
U.S.
EFFECT JANUARY 1, 2010
– Corrects prior ‘glitch’ that penalized US LLCs
owning Canadian entities
– Adds worse ‘glitch’ for U.S. companies owning
glitch US
Canadian ULCs
– Lowers withholding rates for interest

54. FIN 48 – IS FINALLY HERE (?)
• FIN 48
– Requires companies to quantify tax exposures
–D
Does not l k lik i will b d l
look like it ill be delayed (
d (again) f
i ) for
non-public companies
– M t document tax positions and id tif
Must d tt iti d identify
exposures as if you will be audited

55. OBAMA’S PROPOSAL
• WOULD CLOSE SOME PERCEIVED LOOPHOLES IN
THE CURRENT LAW
• WOULD ADD ADDITIONAL PENALTIES FOR
NONCOMPLIANCE.

56. THANK YOU!
KURT PIWKO JIM MANNING
586.416.4948 616.643.4054
KURT.PIWKO@PLANTEMORAN.COM JIM.MANNING@PLANTEMORAN.COM
CURTIS RUPPAL JERRY JONCKHEERE
616.643.4069 616.643.4044
CURTIS.RUPPAL@PLANTEMORAN.COM JEROME.JONCKHEERE@PLANTEMORAN.COM