The CPA Desk

A Thought Leader Production by PKFTexas

How Not-For-Profits Can Prepare for Sudden Outpouring of Support

Jen Lemanski
By Jen Lemanski on Posted in Tax and Accounting Desk

Americans gave unprecedented sums to charity in response to the devastating hurricanes last year. Large organizations, such as the American Red Cross, were equipped to handle the huge influxes of donations. However, some smaller charities were overwhelmed. Although it may seem like an unlikely problem, not-for-profits need a plan to handle a potential outpouring of support.

Know What’s Normal
Perhaps the biggest lesson to learn from recent disasters is to always have an expansion plan in place. When the influx of online giving reached critical mass, many organizations found that their websites overloaded and went offline. Their sites had to be moved to more powerful servers to handle the increased traffic.

Keep track of “normal” website hits, as well as the numbers of calls and email inquiries received, so you won’t be caught off guard when you start to surpass that amount. Also, know your systems’ ultimate capacity so you can enact a contingency plan should you approach critical mass.

Mobilize Your Troops
Having an “early warning system” is only one part of being prepared. You also need to be able to mobilize your troops in a hurry. Do you know how to reach all of your board members at any time? Can you efficiently organize volunteers when you need extra hands quickly? Be sure you have:

  • An up-to-date contact list of board members that includes home, office and mobile phone numbers,
  • A process, such as a phone tree, so you can communicate with the board quickly and efficiently, and
  • One or more emergency volunteer coordinators who can call and quickly train people when you need them.

Also conduct a mock emergency with staff and volunteers to learn where you’re prepared to ramp up and where you’re not.

Build Relationships
A surge in donor interest may mean a surge in media attention. While it might be tempting to say, “not now, we’re busy,” don’t pass up the opportunity to publicize your organization’s mission and the work that’s garnering all the attention.

In most cases, the immediate surge of interest eventually wanes. Before that happens, not-for-profits should start building lasting relationships with new donors and media contacts. Inform them about the work your organization does under “normal” circumstances and suggest ways to get them involved.

What is the Right Accounting Method for Your Tax Purposes?

Daniel Travis
By Daniel Travis on Posted in PKF Texas - The Entrepreneur's Playbook®, Tax and Accounting Desk

The Tax Cuts and Jobs Act (TCJA) liberalized the eligibility rules for using the cash method of accounting, making this method — which is simpler than the accrual method — available to more businesses. Now the IRS has provided procedures a small business taxpayer can use to obtain automatic consent to change its method of accounting under the TCJA. If you have the option to use either accounting method, it pays to consider whether switching methods would be beneficial.

Cash vs. Accrual
Generally, cash-basis businesses recognize income when it’s received and deduct expenses when they’re paid. Accrual-basis businesses, on the other hand, recognize income when it’s earned and deduct expenses when they’re incurred, without regard to the timing of cash receipts or payments.

In most cases, a business is permitted to use the cash method of accounting for tax purposes unless it’s:

  1. Expressly prohibited from using the cash method, or
  2. Expressly required to use the accrual method.

Cash Method Advantages
The cash method offers several advantages, including:

Simplicity. It’s easier and cheaper to implement and maintain.

Tax-planning flexibility. It offers greater flexibility to control the timing of income and deductible expenses. For example, it allows you to defer income to next year by delaying invoices or to shift deductions into this year by accelerating the payment of expenses. An accrual-basis business doesn’t enjoy this flexibility. For example, to defer income, delaying invoices wouldn’t be enough; the business would have to put off shipping products or performing services.

Cash flow benefits. Because income is taxed in the year it’s received, the cash method does a better job of ensuring that a business has the funds it needs to pay its tax bill.

Accrual Method Advantages
In some cases, the accrual method may offer tax advantages. For example, accrual-basis businesses may be able to use certain tax-planning strategies that aren’t available to cash-basis businesses, such as deducting year-end bonuses that are paid within the first 2½ months of the following year and deferring income on certain advance payments.

The accrual method also does a better job of matching income and expenses, so it provides a more accurate picture of a business’s financial performance. That’s why it’s required under Generally Accepted Accounting Principles (GAAP).

If your business prepares GAAP-compliant financial statements, you can still use the cash method for tax purposes. But weigh the cost of maintaining two sets of books against the potential tax benefits.

Making a Change
Keep in mind that cash and accrual are the two primary tax accounting methods, but they’re not the only ones. Some businesses may qualify for a different method, such as a hybrid of the cash and accrual methods.

If your business is eligible for more than one method, we can help you determine whether switching methods would make sense and can execute the change for you if appropriate.

A Closer Look at IC-DISC and Tax Reform

PKF Texas
By PKF Texas on Posted in International Desk, PKF Texas - The Entrepreneur's Playbook®

Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our international tax directors. Welcome back to the Playbook, Frank.

Frank: Well thanks, Jen. Great to be back.

Jen: I know you talk a lot about IC-DISC; how is that impacted by tax reform and can you give us a little overview of IC-DISC again?

Frank: That’s a great question. Kind of backing up, what IC-DISC is it’s a vehicle to provide tax incentives for exports. It’s rather dated – it was originated in the 1970s – but more recently it was used because of the difference between capital gains tax rates and dividends tax rates. Now the dividends tax rates are the same as capital gains rates, it was used to a rate arbitrage. The way it basically was you had to actually set up an IC-DISC entity; let that entity be the exporting entity.

There are different variations, whether a commission DISC or a buy/sell DISC – most people are using the commission DICSs – and the reason was that you didn’t have to change operating procedures around exports and it provided a nice tax benefit. Fortunately the tax reform did not change or repeal the IC-DISC, so that actually is still the law.

Jen:  Great, great. And so are there any considerations from tax reform that do impact it? Has it changed any rates or what does that look like?

Frank: That’s an equally great question. The answer is the benefit with the IC-DISC was really in the rate arbitrage. So now with the changing rates – so if you were an exporting company with an IC-DISC, your effective corporate rate has just gone from 34% or 35% to now 21%. So the rate arbitrage using IC-DISC is not as great – in fact it may actually be nil. If you were using a flow-through entity like an S Corporation with an IC-DISC structure, then there was a rate arbitrage as well, and that’s actually still in play because the top rate for individuals is 37% versus the capital gains rates of 23.8%. So I would say if you have – if you’ve been using an IC-DISC and your operating company is a C Corporation at the 21% rate, I would say there are other strategies to look at.

One for example is the deferral strategy where you accumulate income in the IC-DISC. Now you run into issues with paying a minimum interest charge – where the IC comes in, interest charge – but the strategy around IC-DISC does change for C Corporations, because the rate arbitrage has changed.

Jen: Okay, now for tax planning purposes, are there any other considerations with the new tax reform law? Does anything else impact the IC-DISC?

Frank: I think in addition to what I said regarding the rate arbitrage change, particularly for C Corporations, there’s this new provision we talked about in earlier videos called FDII – the Foreign Derived Intangible Income – where that income is taxed at a 13.165%. That actually can be used side by side or along with the IC-DISC. There’s no double dipping, but there’s some interplay between those two tax relief provisions.

Jen: So if you’re doing exports or considering exporting these are some things you’ll need to be paying attention to?

Frank: Absolutely.

Jen: Perfect. Well, we’ll get you back to talk about some other international topics.

Frank:  Well, thank you. I’d love to do so.

Jen: To learn more about other international topics, visit PKFTexas.com/internationaldesk. This has been a Thought Leader production brought to you by PKF Texas the Entrepreneur’s Playbook. Tune in next week for another chapter.

How to Navigate Your Not-For-Profit During Growth Stage

Chip Schweiger
By Chip Schweiger on Posted in Tax and Accounting Desk

A not-for-profit’s growth stage generally starts two or three years after formation and continues until maturity at around age seven. This period comes with a sense of accomplishment and the opportunity to refine and expand, but these “adolescent” years can pose challenges as well.

Board Shifts
Perhaps the most common marker of a growth-stage not-for-profit is changes in the composition and focus of its board of directors. Boards usually continue to be active in operations to some degree, but also must begin to work on strategic matters — the policies, planning and evaluations necessary for long-term sustainability.

Founding board members may move on at this stage. The result could be a larger and more inclusive group of individuals, preferably with a wider range of skills, talents and backgrounds. Boards also can establish committees at this time.

Staff Expansion
As demand for services builds and you expand programming, staffing needs increase. Adding to staff in the growth stage will help avoid burnout. Your not-for-profit should design a clear organizational structure and hire experienced managers.

You should also develop formal job descriptions. Employees will now be expected to work under formal systems, following policies and procedures and in a more efficient manner. Your organization’s executive director is still the primary decision maker, but he or she may not have time to be as involved in every area.

Mission Adjustment
You might want to adjust your not-for-profit’s mission during the growth stage. Changed demographics or economic developments could make it appropriate to revise your organization’s purpose.

You can home in more intensely on a subset of the original mission or shift focus to another area. For example, a literacy organization that started out helping native English speakers improve their reading skills might expand to include teaching English as a second language. The charity may then develop a strategic plan to incorporate the changes to its mission.

Funding Augmentation
Growth-stage organizations are generally in a more comfortable financial position, with less uncertainty. You may have developed good relations with key funders, but there are still obstacles in securing necessary funding (and cash flow) to support current programming. To maintain growth, you’ll need to diversify revenue sources, manage cash flow and develop solid budgets. We can help you.

The TCJA Prohibits Recharacterization, 2017 Conversions Still Eligible

Emily Smikal
By Emily Smikal on Posted in Tax and Accounting Desk

Converting a traditional IRA to a Roth IRA can provide tax-free growth and tax-free withdrawals in retirement. But what if you convert your traditional IRA — subject to income taxes on all earnings and deductible contributions — and then discover you would have been better off if you hadn’t converted it? Before the Tax Cuts and Jobs Act (TCJA), you could undo a Roth IRA conversion using a “recharacterization.” Effective with 2018 conversions, the TCJA prohibits recharacterization — permanently. But if you executed a conversion in 2017, you may still be able to undo it.

Reasons to Recharacterize
Generally, if you converted to a Roth IRA in 2017, you have until October 15, 2018, to undo it and avoid the tax hit.

Here are some reasons you might want to recharacterize a 2017 Roth IRA conversion:

  • The conversion combined with your other income pushed you into a higher tax bracket in 2017.
  • Your marginal income tax rate will be lower in 2018 than it was in 2017.
  • The value of your account has declined since the conversion, so you owe taxes partially on money you no longer have.

If you recharacterize your 2017 conversion but would still like to convert your traditional IRA to a Roth IRA, you must wait until the 31st day after the recharacterization. If you undo a conversion because your IRA’s value declined, there’s a risk that your investments will bounce back during the waiting period, causing you to reconvert at a higher tax cost.

Recharacterization in Action
Sally had a traditional IRA with a balance of $100,000 when she converted it to a Roth IRA in 2017. Her 2017 tax rate was 33%, so she owed $33,000 in federal income taxes on the conversion.

However, by August 1, 2018, the value of her account had dropped to $80,000. So Sally recharacterizes the account as a traditional IRA and amends her 2017 tax return to exclude the $100,000 in income.

On September 1, she reconverts the traditional IRA, whose value remains at $80,000, to a Roth IRA. She will report that amount when she files her 2018 tax return. The 33% rate has dropped to 32% under the TCJA. Assuming Sally is still in this bracket, this time she’ll owe $25,600 ($80,000 × 32%) — deferred for a year and resulting in a tax savings of $7,400.

(Be aware that the thresholds for the various brackets have changed for 2018, in some cases increasing but in others decreasing. This, combined with other TCJA provisions and changes in your income, could cause you to be in a higher or lower bracket in 2018.)

Know Your options
If you converted a traditional IRA to a Roth IRA in 2017, it’s worthwhile to see if you could save tax by undoing the conversion. If you’re considering a Roth conversion in 2018, keep in mind that you won’t have the option for recharacterization. We can help you assess whether recharacterizing a 2017 conversion or executing a 2018 conversion makes sense for you.

Houston CPA Society’s 16th Energy Conference – Agenda and Registration

PKF Texas
By PKF Texas on Posted in PKF Texas - The Entrepreneur's Playbook®, The Energy Economy

Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m here with Brian Baumler, the Energy Practice Leader at PKF Texas and the Chair of the 16th annual Houston CPA Society Energy Conference. Also with us is Jennifer Poff, the Executive Director of the Houston CPA Society. Welcome to The Playbook, Jennifer and Brian.

Brian: Thank you, Jen.

Jennifer: Thank you.

Jen: So, Jennifer, tell us a little bit about the Society.

Jennifer: The Society has been around for 90 years, and one of the things we’ve done for 90 years is we’ve been the local organization for CPAs to get their continuing education, to share ideas with other people in the profession and just to have an area where they can come network together. One of the things we do for our continuing education is the Energy Conference, and we’re in the 16th year of doing that. With 7,700 members, we have about 350 who attend this conference, making it one of our larger events.

Jen: That’s really great. So, Brian, you’re the Chair and you’ve been the Chair for the past several years. Tell us what you’ve got planned for this year.

Brian: We have a great lineup. As we’ve had in the past, The Big Four are all represented, giving various presentations on technical topics – accounting and reporting, SEC compliance. We’re also covering M&A trends and also taxation. It’s going to be a great event and is going to be well attended.

We also have various panels throughout the day. One is covering the E&P and trying to give everybody perspective on what’s going on in that space. We also have a panel that’s discussing capital markets; we have Tudor, Pickering, Holt & Co. and other home-grown folks represented in that panel. We also have an exciting panel on technology and what trends are shaping the industry within technology and also changing us in our workforce.

Jen: Perfect. Now, I know you’ve had several really big name keynotes in the past. Who is your keynote speaker this year?

Brian: We have Ryan Sitton, who is the Texas Railroad Commissioner. He’s got a lot of energy, is a great presenter and I’m sure is going to have everybody’s attention.

Jen: Perfect. So, when is this conference, where is the conference and what time does it start?

Brian: This year, the conference is going to be on August 29th. It’s going to be at Hilton Americas downtown. The registration starts at 6:45 a.m., the conference actually kicks off at 7:45 a.m. and lasts until about 5:00 p.m. We have a special session at the end – we have John Garrett, who is a recovering CPA, and he’s actually going to talk to us about how we brand ourselves outside of the workforce.

Jen: Perfect. I’ve seen his Green Apple talk – it’s really great. Now, Jennifer, where would somebody go to register for the conference?

Jennifer: They can go to our website www.houstoncpa.org.

Jen: Is there an energy page that they should be looking for?

Jennifer: There are two ways to get the energy page: you can access it through the course catalog, or it’s right on the homepage. When you see the banner at the top, just click the arrow and you’ll see the Energy Conference right there.

Jen: I know you guys can’t do this all by yourselves with the Society. Are there sponsors this year?

Brian: Yes, we have almost 30 sponsors this year. Our underwriting sponsor is WG Consulting, so we’re very excited to have them this year.

Jen: Perfect. Well, thanks, and we’ll see you guys on the 29th.

Brian: Thank you.

Jen: This has been another Thought Leader Production brought to you by PKF Texas The Entrepreneur’s Playbook. Tune in next week for another chapter.

Let’s Revisit Your Not-For-Profit’s Social Media Policy

Jen LemanskiSiri Svay
By Jen Lemanski and Siri Svay on Posted in Marketers IRL, Tax and Accounting Desk

Perhaps you wrote a social media policy several years ago when your not-for-profit set up a Facebook page. Since then, not only has your not-for-profit likely changed, but new social media platforms have emerged. At the very least, the sites you use have probably revised their terms of service. That’s why it’s time to revisit your policy.

The Basics
A social media policy helps ensure that staffers, board members and volunteers use online accounts to promote and enhance — not damage — your not-for-profit’s reputation and fundraising efforts. Without a policy, you risk confusing and offending stakeholders, inviting lawsuits and even incurring financial costs.

To prevent negative outcomes, your policy should address:

  • Which sites you’ll use,
  • Who in your organization has access to them,
  • What subjects they’re allowed to discuss, and
  • Whom they can “friend.”

Also specify whether staffers and board members can discuss their work on their personal social media accounts. If so, require them to post a disclaimer saying that their opinions about your organization are their own.

Evaluate Site Use
As you revisit your social media policy, consider the sites your not-for-profit currently uses and whether they still enable you to reach your target audience. Do your staffers post frequently enough to be effective? Is your follower base growing? If not, you may want to shift resources elsewhere.

Another consideration is whether the social media outlets you use have changed their terms of service. In the past couple of years, many sites have expanded their rights to share user account information with third parties. Such changes may raise privacy concerns within your organization.

Other Updates
Also review who has account access. In general, the fewer people with access, the less likely someone will post something damaging. But, if your not-for-profit is struggling to maintain a regular posting schedule, it might make sense to add new, enthusiastic staffers to the account.

Be sure that, whenever you remove a user from an account, you change the password. Social media sites increasingly are being hacked, so your policy should require longer, more difficult passwords.

Another issue that you can’t afford to ignore these days is intellectual property (IP) rights. Contrary to what some believe, not-for-profits aren’t immune from IP infringement lawsuits. Make sure you have permission from IP holders and properly credit them when you post third-party images, videos, music and text.

Fast-moving Target
These are only some of the many issues that may require you to revisit your social media policy. Social media changes quickly. To use it effectively, pay attention to evolving developments.

What to Consider About Alternative Minimum Tax (AMT)

Renee Kroesch
By Renee Kroesch on Posted in Tax and Accounting Desk

There was talk of repealing the individual alternative minimum tax (AMT) as part of last year’s tax reform legislation. A repeal wasn’t included in the final version of the Tax Cuts and Jobs Act (TCJA), but the TCJA will reduce the number of taxpayers subject to the AMT.

Now is a good time to familiarize yourself with the changes, assess your AMT risk and see if there are any steps you can take during the last several months of the year to avoid the AMT, or at least minimize any negative impact.

Alternative Minimum Tax vs. Regular Tax
The top AMT rate is 28%, compared to the top regular ordinary-income tax rate of 37%. But the AMT rate typically applies to a higher taxable income base and will result in a larger tax bill if you’re subject to it.

The TCJA reduced the number of taxpayers who’ll likely be subject to the AMT in part by increasing the AMT exemption and the income phaseout ranges for the exemption:

  • For 2018, the exemption is $70,300 for singles and heads of households (up from $54,300 for 2017), and $109,400 for married couples filing jointly (up from $84,500 for 2017).
  • The 2018 phaseout ranges are $500,000–$781,200 for singles and heads of households (up from $120,700–$337,900 for 2017) and $1,000,000–$1,437,600 for joint filers (up from $160,900–$498,900 for 2017).

You’ll be subject to the AMT if your AMT liability is greater than your regular tax liability.

Alternative Minimum Tax Triggers
In the past, common triggers of the AMT were differences between deductions allowed for regular tax purposes and AMT purposes. Some popular deductions aren’t allowed under the AMT.

New limits on some of these deductions for regular tax purposes, such as on state and local income and property tax deductions, mean they’re less likely to trigger the AMT. And certain deductions not allowed for AMT purposes are now not allowed for regular tax purposes either, such as miscellaneous itemized deductions subject to the 2% of adjusted gross income floor.

But deductions aren’t the only things that can trigger the AMT. Some income items might do so, too, such as:

  • Long-term capital gains and dividend income, even though they’re taxed at the same rate for both regular tax and AMT purposes,
  • Accelerated depreciation adjustments and related gain or loss differences when assets are sold,
  • Tax-exempt interest on certain private-activity municipal bonds, and
  • The exercise of incentive stock options.

Alternative Minimum Tax Planning Tips
If it looks like you could be subject to the AMT in 2018, consider accelerating income into this year. Doing so may allow you to benefit from the lower maximum AMT rate. And deferring expenses you can’t deduct for AMT purposes may allow you to preserve those deductions. If you also defer expenses you can deduct for AMT purposes, the deductions may become more valuable because of the higher maximum regular tax rate.

Please contact us if you have questions about whether you could be subject to the AMT this year or about minimizing negative consequences from the AMT.

Understanding FDII – Application and Calculation

PKF Texas
By PKF Texas on Posted in International Desk, PKF Texas - The Entrepreneur's Playbook®

Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Frank Landreneau, one of our International Tax Directors. Frank, welcome back to the Playbook.

Frank: Thanks, Jen. It’s great to be back.

Jen: A couple of episodes back we talked about the Foreign Derived Intangible Income incentive. How does that work?

Frank: It’s a pretty convoluted calculation. First, as we talked about last time, a company will identify its gross receipts related to this Foreign Derived Intangible Income – we call it FDII for short.

Jen: FDII, I like that.

Frank: And then, you allocate associated deductions to arrive at net income, and then you look at what is normally looked at as a normal return for a company, which is mechanically derived, is 10% of the adjusted tax basis of the assets. And then, any profits above and beyond that on this income would be excess profits subject to a special rate of tax, which would be 13.125%.

Jen: Ok, so what should companies be doing about this?

Frank: One thing would be to take a look at how they source products. If they’re sourcing product from overseas, could they get it in the United States? Or, if you are, let’s say, a U.S. subsidiary of a foreign multinational, can the foreign multinational source those goods from the United States?

Jen: So, how might this apply to services? We talked about services on a different episode as well.

Frank: A service is also an interesting thing, and we don’t have a whole lot of guidance on that just yet, but essentially it would work the same way. The interesting part is that it does not indicate in the law currently that the services actually have to be performed within the U.S. So, theoretically, they could be performed outside the U.S. as long you are not outside the U.S. long enough to create what we call a permanent establishment. In that case, it would be called branch income; it would not qualify. Intermittent services, like oilfield services, where you may be providing services for a two-week, three-week period but you don’t have a home office there, might apply to this FDII income.

Jen: So, they really should reach out to us and find out if it applies. Now, I know you’ve talked about IC-DISC in the past. Does the FDII impact the IC-DISC at all?

Frank: Interestingly enough, in the tax law change, IC-DISCs were untouched. You can actually use the IC-DISC incentive in conjunction with FDII. The thing to keep in mind is that FDII only qualifies if you are a C-corporation. If you are an S-corporation, sole proprietorship, partnership, you want to also take a look at your tax structure, because this only qualifies for C-corporations.

Jen: Frank, we’ll get you back to talk about that again. Thanks.

Frank: I’d love to come back. Thank you.

Jen: To learn more about other international topics, visit pkftexas.com/internationaldesk. This has been another Thought Leader Production brought to you by PKF Texas The Entrepreneur’s Playbook. Tune in next week for another chapter.

It’s Time to Revisit the Donor Bill of Rights

Annjeanette Yglesias
By Annjeanette Yglesias on Posted in Tax and Accounting Desk

The Donor Bill of Rights was designed about 25 years ago as a blueprint of best practices for not-for-profits. Some critics have since asserted that the rights are out of date or not comprehensive enough. However, revisiting the list’s basic principles can help you build solid relationships with donors — and even boost fundraising.

Here are the 10 rights and what they might mean for your not-for-profit:

1. To be informed of the organization’s mission, how it intends to use donated resources and its capacity to use donations effectively for their intended purposes. This information is the bedrock of your outreach efforts and should be clear to your board, staff and anyone reading your organization’s materials.

2. To be informed of who’s serving on the organization’s governing board, and to expect the board to exercise prudent judgment in its stewardship responsibilities. You must be transparent about who serves on your board, their responsibilities and the decisions they’re making.

3. To have access to the organization’s most recent financial statements. Make your nonprofit’s financial data easily accessible to constituents, potential donors and charitable watchdog groups.

4. To be assured gifts will be used for the purposes for which they were given. Donors expect that you’ll minimize administrative expenses so their funds are available for programming and that you’ll honor any restrictions they’ve placed on gifts.

5. To receive appropriate acknowledgment and recognition. In addition to thanking donors, provide them with the substantiation required for a federal tax deduction and information about the charitable deduction rules and limits.

6. To be assured that donation information is handled with respect and confidentiality to the extent provided by law. Post your organization’s privacy policy on your website and be clear about what information you’re gathering about donors and how that information will be used.

7. To expect that relationships between individuals representing organizations and donors will be professional. Staff and board members should be trained in proper donor interaction — both off- and online.

8. To be informed whether fundraisers are volunteers, employees of the organization or hired solicitors. Again, transparency about your operations is critical.

9. To have the opportunity for donors’ names to be deleted from mailing lists that an organization may intend to share. Donors, not your nonprofit, get to decide whether their information can be shared. Make it easy for donors to opt out of email and other lists.

10. To feel free to ask questions and receive prompt, truthful and forthright answers. Open dialogue between your nonprofit and your donors fosters respect and deepens relationships.

Contact us for help implementing these 10 tenets or developing a customized donor bill of rights.