IRS Issues New Opportunity Zone Guidance and Proposed Regulations

On April 17, 2019, the IRS released highly anticipated additional guidance and proposed regulations concerning investments made under the Opportunity Zone program created under the Tax Cuts and Jobs Act of 2017. The 169-page publication supplements and clarifies many aspects of the initial set of proposed regulations released by the IRS in October 2018 by providing, among other things, significant guidance for investments in qualified opportunity zone businesses (QOZBs) and additional clarity as to how to commence, operate and wind down qualified opportunity funds (QOFs). 

Under the Opportunity Zone program, Congress sought to encourage growth and investment in certain designated low income communities – Opportunity Zones – by providing Federal income tax benefits to qualified taxpayers who invest new capital (i.e., capital gains) into QOFs.  This, in turn, helps fund development/redevelopment projects and/or the development of new businesses therein.

The following represents a summary of some key takeaways of the newly proposed regulations:

Real Estate Developments

  • Unimproved Land – The requirement that the “original use” of tangible property in an Opportunity Zone commence with a QOF will not apply to land, whether improved or not improved. Accordingly, land itself need to be substantially improved; however, the land must be used in connection with the trade or business of the QOF or QOZB.
  • Original Use – The “original use” of tangible property acquired by purchase by any person will commence on the date that the property is first placed in service in the Opportunity Zone in which depreciation or amortization of such property does or can occur. Accordingly, tangible property in an Opportunity Zone that is previously depreciated or amortized by a taxpayer other than a QOF or QOZB would not satisfy the original use requirement.
  • Vacant Buildings – A property’s prior use may be disregarded for the purposes of the “original use” requirement if the existing building (purchased after December 31, 2017) has been vacant for 5 years or more.
  • Working Capital Safe Harbor – QOZBs may extend the 31-month working capital safe harbor if capital deployment delays are attributable to waiting for government action on completed applications that were submitted during the safe harbor period. This clarification is critical for projects located in certain states, such as New Jersey, that can have a lengthy zoning approval process.

Additionally, to help foster the development of new QOZBs in Opportunity Zones, the new regulations expand the working capital safe harbor to apply to QOZB expenditures such as payroll, inventory and occupancy costs during their start-up phases. 

  • Improvements to Leased Property – Improvements made by a lessee to leased property satisfy the “original use” requirement and are considered purchased property for the amount of the unadjusted cost basis of such improvements.
  • Residential Rental Property and Triple Net Leases – The ownership and operation (including leasing) of real property used in a trade or business can be treated as the active conduct of a trade or business; however, merely entering into a triple net lease will not be considered an active trade or business under the Opportunity Zone program.
  • Straddling Opportunity Zones – Certain developments may be located only partially within an Opportunity Zone. If the amount of real property based on square footage located within an Opportunity Zone is substantial as compared to the area of contiguous property outside the Opportunity Zone, the contiguous real property located outside of the Opportunity Zone, then all of the real property would be deemed to be located within the Opportunity Zone. 

Leased Property

Under the Opportunity Zone program, QOZBs can own or lease tangible property for the purposes of satisfying the “substantially all” test (i.e., 70% of the QOZBs property must be “qualified opportunity zone business property”).  Under the proposed regulations:   

  • Improvements made by a lessee to leased property satisfy the “original use” requirement and are considered purchased property.
  • Leased tangible property can constitute “qualified opportunity zone business property” for the purposes of satisfying the 90% asset test and the 70% “substantially all” tests under the regulations, provided that the leased tangible property: (1) is acquired under a lease entered into after December 31, 2017; and (2) substantially all of the use of the leased tangible property occurs in an Opportunity Zone during substantially all of the period in which the QOZB leases the property.
  • Neither the “original use” test nor the “substantial improvement” test is applicable to leased tangible property because a lessee cannot be placed in service for depreciation or amortization purposes as it does not own the property and has no basis therein.
  • Tangible personal property can be leased from a “related” party, provided that (1) the lease is a “market rate lease”, (2) the QOF or QOZB does not make any prepayments under the lease that exceeds 12 months, and (3) the proposed regulations do not permit leased tangible personal property to be treated as QOZB property unless the lessee becomes the owner of tangible property that is QOZB property, and that has a value not less than the value of the leased personal property. Certain anti-abuse provisions were also provided to prevent the use of leases to circumvent the requirement to purchase real property (other than unimproved land).

QOF/QOZB Operations

  • “Substantially All” – The definition of “substantially all” throughout Section 1400Z-2 was clarified to mean:
    • 70% – For determining the amount of usage of QOZB property (including tangible leased property) within an Opportunity Zone.
    • 90% – For measuring the holding period of tangible property or partnership interest or stock in a QOZB, as qualified Opportunity Zone property.
  • Relief for Newly Contributed Assets – QOFs may apply the 90% asset test without taking into account investments received within the preceding 6 months.
  • Reinvestment of Interim Gains – QOFs are given 12 months to reinvest the capital derived from the date of sale of qualified opportunity zone stock, qualified opportunity zone partnership interests or other tangible qualified opportunity zone property.
  • QOF Investments – Must be in the form of cash or property, not services, in order to achieve the tax benefits provided under the Opportunity Zone program.

QOZB Gross Income Test

  • In order to qualify as a QOZB, at least 50% of the QOZBs total gross income must be “from the active conduct of such business” within an Opportunity Zone. The proposed regulations provide three safe harbors (of which only one needs to be satisfied) as well as a facts-and-circumstances test to determine whether a QOZB satisfies the gross income requirements.
  • At least 50% of the services performed (as measured by hours worked) for the QOZB by its employees and independent contractors must occur within the Opportunity Zone.
  • At least 50% of the services performed (as measured by the amounts paid for the services performed) for the QOZB by its employees and independent contractors must occur within the Opportunity Zone.
  • The tangible property of the QOZB and the management or operational functions performed for the QOZB that are located within an Opportunity Zone are necessary for the QOZB to generate 50% of its gross income.
  • Even if none of the aforesaid tests can be satisfied, if based on all facts and circumstances, at least 50% of the gross income of a trade or business is derived from the active conduct of a trade or business within an Opportunity Zone, the 50% gross income requirement could be satisfied.

Other Matters

  • Intangible Property – Under the Opportunity Zone program, a “substantial portion” of the intangible property of a QOZB must be used in the active conduct of a trade or business within an Opportunity Zone, which is defined as “40%” under the proposed regulations.
  • Inventory in Transit – Inventory (including raw materials) of a trade or business does not fail to be used in an Opportunity Zone solely based on the fact that it is in transit either (1) from a vendor to the QOZB’s facility in an Opportunity Zone or (2) from the QOZB’s facility located in an Opportunity Zone to customers outside of the Opportunity Zone.
  • Inclusion Events – Section 1400Z-2(b)(1) provides that the amount of gain that is deferred if a taxpayer makes an equity investment in a QOF will be included in the taxpayer’s income in the taxable year that includes the earlier of (i) the date on which the qualifying investment is sold or exchanged (i.e., an “Inclusion Event”) or (ii) December 31, 2026. Certain Inclusion Events are delineated in the newly proposed regulations, including the taxable disposition (i.e., sale) of certain QOF partnership or stock interests and transfers by gift of qualifying investments, and the distribution to a partner of a QOF partnership or property that has a value in excess of the basis of the partner’s qualifying QOF partnership interest. 

The IRS is now accepting written comments concerning the newly proposed regulations, with a public hearing scheduled for July 9, 2019.  We will continue to evaluate the newly proposed regulations and monitor their impact on new developments and new businesses within Opportunity Zones. 

If you wish to explore potential opportunity zone opportunities in New Jersey or have questions concerning the content of this Client Alert, please contact the author, Matthew J. Schiller.

What is an H-1B Audit?

If you are an employer of a person who has an H-1B visa, you may face an audit and investigation by the U.S. Department of Labor (DOL). DOL is cracking down on any suspected abuse of the H-1B visa program and has kicked up investigations into high gear. Facing a DOL audit and investigation may be stressful and you may have no idea what to expect which will exacerbate the stress you already feel. NPZ Law Group assists clients nationwide with DOL investigations and audits. Our knowledgeable Immigration and Nationality attorneys can answer any questions you or your staff may have about the entire process.

What is an H-1B Audit and Investigation?

The Immigration and Nationality Act (INA) created the H-1B visa classification. It provides for the temporary employment of foreign workers in the United States who are engaged in specialized occupations requiring higher-level education degrees. The law is specific regarding the requirements and standards for both those employers and employees who are participating in the H-1B Visa program. The responsibilities of overseeing H-1B visas fall among various government agencies. The DOL’s Wage and Hour Division (WHD) is one such supervising agency.

When an employer files the petition for an H-1B visa, the employer must agree to comply with labor conditions included in the Labor Condition Application. Failure to comply with these conditions can trigger an audit and investigation by the WHD and other supervising agencies and divisions. Specifically, WHD is tasked with making sure employers are paying H-1B visa workers the wage that was disclosed in the Labor Condition Application. WHD also has the responsibility of ensuring that the H-1B employees are in the occupation and the location that was specified on the application.

Among other things, an audit and investigation by WHD may include a site visit. WHD wants to ensure that the employee is working the listed job at the listed location. WHD also wants to investigate the job duties of the employee. In addition to the site visit, WHD will likely want to review things like:

  • Whether the employer made the appropriate inquiries regarding the availability of a U.S.
  • Worker for the employment position;
  • Whether the employer is paying the designated wage listed in the application;
  • Whether the employee is receiving the employment benefits he or she should be; and
  • Verification of the employer’s dependency status

WHD investigations are adversarial in nature. A determination letter will be issued after an investigation and every determination contained therein may be appealed. The employer will be notified of the opportunity for a hearing to be held 60 days after the determination letter has been issued.

If found to be in violation of the requirements of the H-1B visa program, an employer may be required to do things such as pay back wages to displaced workers or reinstate a displaced U.S. worker. A civil monetary penalty may also be assessed and could be anywhere between $1,000 and $35,000 per violation.

Helping Employers Protect Themselves in the Event of an H-1B Audit and Investigation.

As an employer participating in the H-1B visa program, you have very specific requirements with which you must comply. DOL is very quick to trigger an investigation if there is even the slightest chance that fraud may be occurring. The dedicated attorneys at Nachman, Phulwani, Zimovcak Law Group, P.C., will help you through this process and get you prepared for anything that may happen during or as a result of a DOL audit and investigation.

If you should have any questions or need more information about the ways in which the U.S. Immigration and Nationality Laws may impact you, your family, your friends or your colleagues, please contact the U.S. Immigration and Nationality Lawyers at the NPZ Law Group – VISASERVE – U.S. Immigration and Nationality Lawyers by e-mailing us at [email protected] or by calling us at 201-670-0006 (x107). You can also visit our Law Firm’s website at

Employers – Tip the Benefits Scale in Your Favor

With the unemployment rate at all time lows around 4%, the fight for top talent across any industry is more difficult than ever.  The most successful employers recognize that their most valuable asset is their employees, yet so does the competition down the street playing in the same labor pool.  One very effective component to attract and retain the best is to offer and communicate a robust Total Compensation Plan that includes a broad array of employee benefit solutions.  Today, most employers have employees ranging from their early 20s to individuals into their 60s – a broad range.

One size doesn’t fit all.  The needs, wants and ability of Gen Z is completely different than the Baby Boomers.  A requirement is offering a broad assortment of medical.  Worth mentioning, in case overlooked, an employer should offer plans ranging in scale of premium from low to high.  The high deductible plans appeal to Gen Z, who are looking to maximize dollars in their paycheck but also not as likely to need medical attention.  Where the rich PPO/POS plans appeal to baby boomers and individuals who are starting a family, their lower copays and out-of-pocket expenses are a big benefit.

Beyond the medical though, employers would be wise to consider the following:

  1. Tuition Reimbursement or Student Debt Repayment – a great way to attract millennials and Gen Z who want to get a bachelor or master’s degree.  These programs are gaining in terms of employers offering but adoption is still relatively low at between 5-10% of employees utilizing.
  2. Telehealth – inexpensive and more convenient way to receive medical care.  Instead of a regular doctor visit, scheduling and waiting at the office, you log on through video call on your cell phone or computer.  Most insurance companies have already integrated Telehealth into their standard benefit offering but employers and their partners are not communicating enough.
  3. Care/Patient Advocacy – more than 50% of large employers offer this service, but it is readily available to businesses of all sizes.  Employees understandably become distracted by large medical claims in their immediate family.  Having an advocate or coach to help the family navigate the complex healthcare landscape is a huge advantage to the employee and employer.
  4. Wellness Programs – A well run wellness program is a must.  These run the gamut from smoking cessation, diabetes management, weight loss and preventive health screenings.  It is important to have an active wellness committee and senior management buy-in to the process.
  5. Discounts on goods and services – third parties offer access to discounts on travel, movies, and many other consumer purchases. 
  6. Fitness Memberships/Gym Utilization Discounts – some insurance companies offer discounts if employees utilize their gym 3 days a week.  Other employers are partnering with local/national gyms to secure group discounts on memberships.
  7. Ancillary Benefits (life and disability) – continues to evolve and be a very affordable addition.  Plans are reaching beyond the traditional 60 years of age and going up to 70s.  Employers can offer some base coverage and allow employees to buy additional at a “group discount”.
  8. Retirement Plans – are your employees “retirement ready”?  Many employers are now opting new employees into the retirement plan, to help increase participation and assist employees in their retirement efforts. 

Most important is the communication of these programs.  Employers should utilize online benefit administration tools to communicate to the younger generation and have print copies available for the population that doesn’t access online.  Most employees don’t appreciate the total contribution employers are making, partly because they are not utilizing the majority of the above but also for those that are missing the opportunity to demonstrate the value. 

Get Out of Debt and Do It Right

Debt is a big and growing problem with consumers in the United States and there are various strategies you can use in dealing with it. Such effective methods are settling debt, paying off higher interest rate debt first, working out payment plans and lastly, filing for bankruptcy.

Consumers often times make many mistakes when dealing with debt and in this article I will attempt to lead you to the best way to deal with debt in the right way from knowing the causes of debt, avoiding common mistakes in paying off debt and answering questions regarding bankruptcy.

Causes of Debt

Causes of debt that may have gone out of control are numerous.  Some examples for the  cause of  debt are (1) medical problems, an injury or sickness leading to high medical debt, (2) loss of a job or decrease in income, (3) divorce or separation, (4) interest rates on credit cards out of control, (5) adjustable mortgage rates skyrocketing monthly payments, (6) falling behind on mortgage payments, (7) business failures, (8) senior citizens on fixed income with no way to make additional money and (9) permanent disability with no ability to earn money.

The list of causes could go on and on, but most of the time the debt situation is something beyond your control and you must develop a strategy on paying it off or wiping it out.  Do not feel bad or guilty as you try to deal with your situation and not just ignore the problems and hope they go away. Meeting the debt issues head on are always the best way to avoid making mistakes in dealing with debt.

Mistakes on Paying Off Debt

It is important not to make the wrong decisions in paying off debt.  One common and major mistake often seen is to liquidate retirement accounts in order to pay off credit card, medical bills or other unsecured debt. Unsecured debt is the type of debt that does not have collateral to secure the loan. A mortgage or car loan is an example of secured debt and a credit card is an example of unsecured debt. You never want to pay unsecured debt before secured debt unless you are not concerned with losing the  asset you owe money on.

Retirement accounts are exempt in many states and in all bankruptcy cases so you never want to liquidate those accounts to pay off creditors when you are in trouble because creditors will have no way of going after those assets so long as they remain in a qualified retirement account. The problem arises when you convert that retirement account to cash and put that cash in a bank account then it loses the protection it had previously.  

Creditors cannot touch qualified retirement assets so do not create a situation where the creditor can get the money. If you decide to pay creditors and try to reorganize without bankruptcy always focus on paying secured creditors first.  A secured creditor can foreclose on collateral such as a house or repossess a car that the loan is secured by. Therefore, you always want to pay the secured creditor first in order to protect your asset – like a car or house.

Once you have paid secured creditors first and if you still have sufficient funds then you can pay towards your credit cards. It’s worth noting that you should pay credit cards with higher interest rates first before paying credit cards with lower interest rates. Also, try calling your credit card companies and see if they will reduce the interest rate or waive it while you make payments. If you are trying to avoid bankruptcy and work things out, debt arising from medical treatments is usually the most likely to set up a payment plan or settlement. Focus on paying off medical debt after credit cards and other creditors if deciding to avoid bankruptcy all together. 

We never advise that you work with debt consolidation companies as most of them are scams.  Be very careful before agreeing to have a debt consolidation company help manage your debt. At a minimum, research the company first and consult with a bankruptcy attorney in your area to see if the company is reputable. If the debt appears beyond your control, you should consult with a bankruptcy attorney before making any payments. You want to hold off from making payments because if you decide to file bankruptcy you will be throwing money away on any creditors you did pay before the bankruptcy.  Most bankruptcy attorneys offer a free consultation so it is certainly worth at least a call to explore your options.

Pros and Cons of Filing Chapter 11 and 13 Bankruptcy

The most common bankruptcy chapters for consumers are Chapter 7 and Chapter 13.  Chapter 7 is generally for those persons that have no significant assets and are under a certain median income level so that they are eligible. Chapter 13 is primarily used by consumers who do have assets that they wish to save or their income is over a certain median income level so that a percentage of their debt has to be paid.  Chapter 7 or Chapter 13 can be used in dealing with business debt also, but most of the time these chapters deal with consumer debt.

In Chapter 7, you can have assets such as a house or car as long as the value is within your allowable exemptions. Thus, you can still file for bankruptcy, keep your house, car or other assets and wipe out all of your other debt. This all depends on the value of your assets. 

To qualify for Chapter 7, your income must also be below the median income level in your state.  If your income is over the median income level then you must go through means testing, which involves taking your allowable deductions off of your income under the applicable IRS guidelines. Even if you are over the median income level you may still qualify for a chapter 7 bankruptcy if after going through the means test no excess income remains.

The median income level for Chapter 7 may not have to be considered if your debts are not consumer related.  For example, if you have debt arising from a failed business that is not consumer debt it may not matter if you are over the median income level. There are still other legal issues to consider in the business debt situation so consultation with an attorney is essential.

In a Chapter 7 you pay nothing and your creditors are wiped out. Chapter 7 only takes about 3 to 4 months from filing of the case to obtaining a discharge order to wipe out your debt. 

By contrast, in Chapter 13 you typically pay a percentage to creditors over a 36 to 60 month plan.  You make one monthly payment to the Chapter 13 Bankruptcy Trustee and the trustee disburses to creditors on a pro rata basis depending on your percentage plan.  For example, if you are paying 10% to all of your creditors, you make one monthly payment and the trustee disburses money to the creditors. At the end of your plan the remaining 90% you owe to the creditor is wiped out.  So, if you owed $100,000 in credit cards, the creditors would receive $10,000 and $90,000 would be wiped out.

In terms of effect on credit, chapter 13 lasts only 7 years on your credit under the Fair Credit Reporting Act and a Chapter 7 lasts up to 10 years.  Please keep in mind that you will be able to get credit shortly after the bankruptcy but it just means that the bankruptcy may be reported on your credit for this length of time. Stated another way, you will not have to wait either 7 or 10 years to get credit. We have seen clients rebuild their credit scores quickly after bankruptcy. The bankruptcy, however, does have a negative impact on your credit scores under either chapter.

In Chapter 7 or 13, the automatic stay is an automatic court order that is entered as soon as you file for bankruptcy.  All collection efforts of creditors are stopped. Some actions a creditor cannot take are:

  • garnishing and taking money from your pay
  • levying with a court order and turning money from your bank accounts
  • foreclose and take your house by sheriff sale
  • repossess your car or other assets
  • proceeding with a lawsuit and obtaining a judgment
  • placing a lien on your assets

It is critical to explore all of your options and strategies with a bankruptcy attorney to determine your best course of action. Even if you decide against filing bankruptcy it is still worth the call to best discuss how to restructure your debt without bankruptcy. Please feel free to contact our bankruptcy attorneys in one of our New Jersey offices, located in Passaic, Hudson, Essex and Bergen counties by calling us at 888-412-5091.

Simple, Smart Changes to Make the H-1B Visa Program Work Better

U.S. Citizenship and Immigration Services (USCIS) today (3/19/2019) announced the start of the fiscal year (FY) 2020 H-1B cap season, start dates for premium processing of cap-subject H-1B petitions, and the launch of its new H-1B data hub, while reminding petitioners of its new H-1B cap selection process. These new efforts underscore the agency’s commitment to supporting President Trump’s Buy American and Hire American executive order designed to protect U.S. workers.

“USCIS continually strives to improve the administration of the H-1B program and make it work better for employers, our agency, and U.S. workers,” said USCIS Director L. Francis Cissna. “We are also committed to fulfilling the president’s Buy American and Hire American executive order, one of the principal goals of which is to protect the interests of U.S. workers in the administration of our immigration system, in part by promoting the proper functioning of the H-1B visa program. Our new H-1B data hub will make information more accessible to the public, and the new selection process will help make the system more meritorious and better protect the wages of U.S. workers.

Additionally, our two-phased approach to premium processing will make the process more effective and efficient for employers and USCIS.”

Start of FY 2020 Cap Season
USCIS will begin accepting H-1B petitions subject to the FY 2020 cap on April 1, 2019, and will reject any FY 2020 cap-subject H 1B petitions filed before April 1. H-1B petitioners must follow all statutory and regulatory requirements as they prepare petitions to avoid delays in processing and possible requests for evidence. Form M-735, Optional Checklist for Form I-129 H-1B Filings, provides detailed information on how to complete and submit an FY 2020 H-1B petition.

Premium Processing for FY 2020 Cap-Subject Petitions
Premium processing will be offered in a two-phased approach during the FY 2020 cap season so USCIS can best manage the premium processing requests without fully suspending it as in previous years. The first phase will include FY 2020 cap-subject H-1B petitions requesting a change of status and the second phase will include all other FY 2020 cap-subject petitions.

Starting April 1, FY 2020 cap-subject H-1B petitioners requesting a change of status on their Form I-129, Petition for a Nonimmigrant Worker, may request premium processing by concurrentlyfiling Form I-907, Request for Premium Processing Service. However, to prioritize data entry for cap-subject H-1B petitions, USCIS will not begin premium processing for these petitions immediately. USCIS will begin premium processing for these petitions no later than May 20, 2019, and will notify the public before premium processing begins for these petitions. If a petitioner does not file Form I-907 concurrently with an FY 2020 H-1B cap-subject petition requesting a change of status, the petitioner must wait until premium processing begins to submit Form I-907. Until premium processing begins for these petitions, USCIS will reject any Form I-907 that is not filed concurrently with a cap-subject Form I-129. Petitioners must appropriately select response “b” for Item 4 in Part 2 of Form I-129 to be eligible to concurrently file Form I-907.

Premium processing for all other FY 2020 cap-subject H-1B petitions will not begin until at least June 2019. Cap-subject petitioners not requesting a change of status may not submit their premium processing request concurrently with their H-1B petition. These petitioners will be eligible to upgrade to premium processing by filing Form I-907 once premium processing begins for this group. USCIS will notify the public with a confirmed date for premium processing for cap-subject petitioners not requesting a change of status.

At this time, premium processing for H-1B petitions that are exempt from the cap, such as extension of stay requests, remains available.

The H-1B program allows companies in the United States to temporarily employ foreign workers in occupations that require the application of a body of highly specialized knowledge and a bachelor’s degree or higher in the specific specialty, or its equivalent. Congress has set a cap of 65,000 H-1B visas per fiscal year. An advanced degree exemption from the H-1B cap is available for 20,000 beneficiaries who have earned a U.S. master’s degree or higher from a U.S. institution of higher education. The agency will monitor the number of petitions received and notify the public when the H-1B numerical allocations have been met

New H-1B Data Hub
USCIS is also announcing the new H-1B Employer Data Hub that will be available on on April 1. The data hub is part of USCIS’ continued effort to increase the transparency of the H-1B program by allowing the public to search for H-1B petitioners by fiscal year, NAICS industry code, company name, city, state, or zip code. This will give the public the ability to calculate approval and denial rates and to review which employers are using the H-1B program.

New H-1B Cap Selection Process
In January, the Department of Homeland Security announced a final rule amending regulations governing cap-subject H-1B petitions, including those that may be eligible for the advanced degree exemption. The final rule reverses the order by which USCIS selects H-1B petitions under the H-1B regular cap and the advanced degree exemption, which will be in effect for the FY 2020 cap season. This simple change increases the chances that more of these visas will be granted to those with an advanced degree from a U.S. institution of higher education.

If you should have any questions or need more information about the ways in which the U.S. Immigration and Nationality Laws may impact you, your family, your friends or your colleagues, please contact the U.S. Immigration and Nationality Lawyers at the NPZ Law Group – VISASERVE – U.S. Immigration and Nationality Lawyers by e-mailing us at [email protected] or by calling us at 201-670-0006 (x107). You can also visit our Law Firm’s website at