January 14, 2025 • 28 mins
About the Guest: Kareyna Miller
Kareyna is a Michigan-based Certified Public Accountant (CPA) noted for her expertise in the cannabis industry. She has been practicing since 2011 and entered the cannabis sector in 2016. Kareyna is highly regarded for her knowledge in cannabis-related tax and accounting compliance and is recognized as an authority in handling the complex issues surrounding cannabis industry taxes and financial attestations. She actively participates in educational initiatives for cannabis professionals and maintains involvement in industry groups and resources.
Episode Summary:
In this episode, hosts John and Chris delve into the intriguing dynamics of cannabis industry taxation. This episode features a detailed discussion with Kareyna Miller, CPA, who addresses the nuanced relationship between cannabis and taxes. The exploration is timely given that changes in regulations and federal classifications could impact industry finances. The core discussion reveals essential tax considerations and implications that businesses within the cannabis industry face, drawing significant insights from Miller's experience and expertise.
Throughout the conversation, the dialogue reveals the intricacies of operating within a highly regulated industry. The cannabis sector's unique tax challenges arise from federal classifications, chiefly the implications of IRS Code §280E. This legislation prohibits cannabis-related businesses from deducting ordinary business expenses, setting the stage for a fascinating exploration of accounting strategies these businesses employ to remain compliant and economically viable. As potential reclassification from Schedule 1 to Schedule 3 looms, the podcast underscores the significance of forthcoming legal changes and how these could reshape financial strategies within the sector.
Key Takeaways:
- Unique Taxation (280E): Cannabis businesses struggle with IRS Code §280E, which limits tax deductions to only cost of goods sold due to federal classification as a Schedule 1 controlled substance.
- Potential Regulatory Changes: Reclassification of cannabis could potentially alter tax liabilities, creating new financial landscapes for industry players.
- Transactional Compliance: Industry participants, including vendors and landlords, must be aware of their tiered roles and related banking challenges.
- Early Professional Involvement: Engaging a knowledgeable CPA early can mitigate complex tax and regulatory missteps.
- Resource Utilization: Leverage state-specific resources and social media groups for guidance and industry networking.
Notable Quotes:
- "Michigan operators are required to have an attestation every three years, and the state puts together agreed-upon procedures for compliance." – Kareyna Miller
- "Cannabis is a Schedule 1 controlled substance at the federal level, so they're subject to a tax rule called 280E." – Kareyna Miller
- "Early engagement with a CPA can prevent regulatory missteps and ensure proper financial set-ups from the start." – Kareyna Miller
- "Banks want to know what they call tier 2 or tier 3 to understand financial flows linked to cannabis businesses." – Kareyna Miller
- "It's not just waking up one day and deciding to start; compliance and capital demands are intense in cannabis." – Kareyna Miller
Episode Sponsor:
REPStracker
www.repstracker.com/affiliate/teachingtaxflow (CODE: IFG)
Listeners are encouraged to explore the full episode to deepen their understanding of the intriguing tax dynamics within the cannabis industry. Stay tuned for future episodes from
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Intro (00:01):
Hey, everyone, and welcome back to the Teaching Tax
Flow podcast episode 118 today.We're gonna look at cannabis and
taxes, what it means for theindustry, hopefully take some of
the confusion or interest thatyou have and make some sense of
it here with a great guest wehave coming up. But before we do
that, let's take a brief momentand thank our episode sponsor.
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John Tripolsky (00:59):
Alright, everybody. Welcome back to the
Teaching Tax Flow podcast. Asyou heard in the intro or read
in the show description, today,we're gonna talk about something
pretty unique that you may nothave expected from us. So,
obviously, we're gonna dive intothe world of cannabis. Not the
details of the industryspecifically, but how it relates
(01:19):
to taxes.
So if it's something that youhaven't thought thought about,
whether you're in the industry,thinking about going into the
industry, you're thinking aboutinvesting in the industry,
you're a user, you're not auser, etcetera. Just even based
off any interests, this is agood one to listen to because
you might start to connect somedots, if we will, just how some
(01:41):
specific industries do pose somechallenges and opportunities
when it comes to taxes. So asalways, we brought not only this
guy that if you're watching, youcan see, but we brought on a
great guest, which I'll letintroduce here shortly. But,
Chris, you know, as I alwayssay, welcome back to your own
show, sir. How's it going?
Chris Picciurro (01:58):
Thanks, John. Oh, jeez. It's so great to see
you again, John.
John Tripolsky (02:01):
Oh, I know. Look at that.
Chris Picciurro (02:02):
There was
John Tripolsky (02:03):
I am unblushing again. Here I am unblushing.
Chris Picciurro (02:05):
I know. I know. No. It's great to be be back.
I'm excited about this topic.
This is a topic you might thinkto yourself, well, cannabis
industry, that's not a well,this is yeah. How many people
does that affect? Ultimately, itaffects anyone that operates or
works in that industry. So we'regonna talk about owners of some
of businesses in that industry.We're gonna talk about employees
(02:25):
of of in that industry.
We're also gonna talk aboutvendors. So, you know, what
happens if you own a piece ofproperty and you rent it out to
someone in the cannabisindustry? Does that is there a
play role? And then and then,talk through this on a federal
level. We know that each eachstate's a little bit different,
but we could touch on that.
We have an amazing guest, so I'mgonna be quiet. Bringing in
(02:46):
Karina Miller, a CPA based outof Michigan, and we've met many
years ago with through theMichigan Association of CPAs.
She, in my opinion, is theauthority on cannabis industry
tax and actually accounting,attestation, which we'll touch
on a little bit. Karina, welcometo the Teaching Tax Flow
podcast.
Kareyna Miller (03:06):
Thank you, Chris. I'm excited to be here.
Chris Picciurro (03:09):
Can you tell us about yourself and and what how
you know, what led you to becomea a CPA and then ultimately
niche into this industry?
Kareyna Miller (03:18):
Sure. So I I started in the cannabis industry
in in late 2016, so it's it'sbeen a little while now. I got
my CPA license, 2011, so 5 yearsearlier. I went it was a
college. I had a professor who,you know, it was, between
finance and accounting, and, youknow, the their encouragement
(03:40):
was to go into the accountingfield.
So that's what I did, and then,got my start with a a regional
firm here. You know, was therefor, enough time to get my CPA
and to, you know, to see to seehow things worked, and then I I
ended up going into privateindustry, and then into cannabis
after that.
Chris Picciurro (04:03):
Awesome. And and tell us about kind of the
the type of clients youtypically work with, both on a
maybe a tax compliance side, butalso a little bit about, you
know, accounting, attestation. Iknow I'm using the term
attestation. Many of you don'tyou're kinda looking your at
your phone or your computer orwhatever right now saying, why
is this got what is attestation?But we're gonna create a break
(04:23):
that down in a little simplerterms.
Kareyna Miller (04:26):
Sure. Sure. So, two sides to it. So there's, I
have my my core client group whoI I like to call them managed
advisory services. It's it'soverseeing their accounting,
their tax advisory, their taxpreparation, kind of everything
that they need.
I work with small businesses,mostly based in Michigan,
(04:49):
primarily growers andprocessors, and then, a few
retailers as well. Theattestation side is different.
So so attestation, the the CPAhas to be independent. The way I
explained that to a client isthey they don't do anything with
your books. They're not, youknow, helping you with with the
(05:09):
details of your tax planning,your advisory.
There there's somebody probablythat you've never met or or
know, you know, haven't workedwith, you know, somebody,
completely unbiased to yourbusiness. And then they come in,
you know, and and do, anattestation looking over your
your records and making surethey're compliant. So you need
(05:32):
somebody who who isn'toverseeing those to to be able
to attest to them.
Chris Picciurro (05:37):
And so a lot of people and I know you're
specifically in Michigan. Solet's just talk about the
Michigan rules and and eachstate's different. But it's
similar if you're listening,similar to a lot of contractors.
So a lot of contractors need aCPA to come in and kinda put
their their eyes on on yourfinancial statements. And
depending on the size in thecontractors, view, depending on
(06:00):
the size of the entity and thatsort of things, it'll dictate
how much the CPA has to leaninto the financials and how much
time they're putting into it andand testing that they are
accurate.
Can you kind of tell us on afrom a 30,000 folk view in in
the state of Michigan becausethere's a lot of regulation in
this industry. What are some ofthe requirements for someone in
this industry?
Kareyna Miller (06:21):
So Michigan, operators are required to have
an attestation every 3 years,and the the state, puts a a form
together with, it's a set ofagreed upon procedures. So it's,
procedures that the CPA isperforming to to look at your
records to make sure they'recompliant. You know, high level
(06:44):
view, you need to make sure thatyou have all the receipts for
your transaction. So it's a ruleto have and keep your vendor
receipts. So even if it's, youknow, going out for lunch or the
gas station, you know, the therole is to have your receipts.
So even those types oftransactions can be looked at.
Chris Picciurro (07:03):
Awesome. And and if when should someone let's
say you're in this industry as aas a retail person, a processor,
or a grower. When should theystart establishing a
relationship with the CPA in inin building their team out? You
know, CPA bookkeeper, I know youyou have a a great suite of
services that you could provide,but not all CPAs or necessarily
(07:25):
are going to or enrolled agentsfor that matter, do the
bookkeeping in the payroll. Butwhen should they start looking
for that that that firm or thatperson to help them out with it?
Kareyna Miller (07:37):
I I would say at the beginning. So I I think a
lot of clients defer to workingwith an attorney as their first
professional service provider,and they're helping them with
with lease agreements, operatingagreements that have tax matter
sections. And a lot of times Isee a client won't engage a CPA
until long after these types ofagreements to to get their
(08:01):
business started are signed, andand they don't realize exactly
what those agreements mean froma from a tax perspective. So,
you know, do you, for myself, Itend to answer questions. You
know, if somebody called me andsaid, I'm I'm looking at getting
into cannabis.
You know? Can you talk with mefor a few minutes? I I usually
(08:21):
give give some advice. You know,I I don't, you know, I I try to
help. So I would say at leasttry to talk with the CPA in the
beginning.
May maybe you're not, you know,consulting with them on a formal
hourly basis, but at least atleast have that opinion next to
to your, you know, theagreements and things that
you're looking at to get yourbusiness started.
Chris Picciurro (08:43):
And no. That's that's a great advice, and I
think it that transcends a lotof different industries. We see
sometimes people probably betteroff looking for professional
advice, early than too late.And, so if someone is coming so
what are some of the unique taxrules related to the cannabis
industry and in some of therecent potential developments
(09:05):
going on, and then we'll starttalking about some of the other
segments. But specifically rightnow for someone that is
operating a cannabis basedindustry, what yeah.
What are some of the unique taxrules? And and, again, is there
anything coming down thepipeline potentially to change
that?
Kareyna Miller (09:21):
Sure. So the most unique tax rule is, you
know, businesses that are arecannabis. Cannabis is a schedule
1 controlled substance at at thefederal level. So they're
subject to a a tax rule called,280 e, which disallows them from
taking ordinary necessarybusiness expenses. So if you if
(09:42):
you think about, you know, thosetypes of expenses, marketing,
payroll, in some cases, youknow, you're limited, pretty
heavily.
Now from an operator perspectiveand from a a tax professional
perspective, you you are allowedto take your cost of goods sold.
So so to me, that's where thethe fun part kinda comes in,
(10:03):
especially if you are a a groweror processor. You know, there's
there's a specific inventoryregulation that that lists all
the all the costs, you know,that that can be included in
your inventory. So just spendingthe time with the client early
on to get their their accountingchart of accounts set up right
to capture all these costs. Youknow, you're going on the
(10:27):
accrual method of accounting.
So this isn't cash based for forthese operators unless they make
a change of accounting methodelection. So so you have some
complexities there to, you know,make sure you're capturing those
costs and then make sure you'reyou're writing them off properly
as your inventory product issold. Operators, you know, I I
(10:50):
would say, you know, especiallyif you're a grower or processor,
make make sure your CPAunderstands those inventory
regulations because there'sthere's a lot of opportunity for
capturing costs. And if the CPAisn't familiar with that,
they're they're likely to missthings, you know, for you.
Chris Picciurro (11:10):
No. Absolutely. So for for most taxpayers, the
cost of goods sold is for a lotof people with inventory, that's
one of their largest deductions,maybe their largest deduction.
And then, however, they'rethey're able to deduct all other
ordinary necessary businessexpenses. For someone in this
industry right now, they canonly deduct the cost of goods
sold.
But like Karina said, you'vewe're working with the right CPA
(11:31):
firm, right tax professionalthat really understands the
rules. They're gonna be able topotentially capture other
deductions that could beconsidered cost of goods sold,
and offset your taxable income.Because when you're paying tax
on your your income minus costto get sold and not your other
expenses, it gets really, reallyexpensive. So, and and that is
based on the, the Department ofJustice, how they classify
(11:56):
cannabis at this point, Ibelieve. But there is a
potential of reclassification.
I know we're at at the time ofthis recording, that those
proceedings were kicked down theroad a little bit. But if if if
it's a is it a schedule 1 andthey're thinking about moving it
to a schedule 3, or am I,trusting my memory too much?
Kareyna Miller (12:17):
That's correct. The the department of, human
health services recommended,moving cannabis to schedule 3.
Now then this was back,springtime of last year. So the,
they they went through a commentperiod session over this. They
had a hearing, on December 2nd,so so little over a month ago at
(12:40):
the time of this recording.
But they didn't have expertwitness testimony there, so they
couldn't complete the hearingprocedures and then pushed it
off. So so there is potential,you know, if it was rescheduled
to schedule 3, you know, youhave the where 280 e only
applies to schedule 1 andschedule 2. But then you get
(13:01):
into, you you know, schedule 3.And and if my memory is serving
me right, that's the sameschedule as, you know, codeine
and and other types ofpharmaceuticals like that. And
there there's no adult use,recreational use for for
pharmaceutical.
Chris Picciurro (13:18):
Right.
Kareyna Miller (13:18):
You know? So so there there's still some
regulatory, you know, issuesthey're gonna have to work out
if if they do, push it toschedule 3.
Chris Picciurro (13:28):
Well, Karina, they they should have gotten
your number for experttestimony. So shame on them for
not using the resources teachingtax law has. That's what I have
to say. Right.
John Tripolsky (13:36):
So, Karina, a couple of questions for you too.
So, you know, I'm I'm gonna makethe assumption that majority of
our audience that's listening tothis probably isn't in the
industry. Again, depending ontheir geographic location,
they're probably surrounded bythe industry one way, shape, or
form. And then, you know,obviously, there's a lot of
interest that goes around this.So I don't know the best way to
(13:57):
really ask as far as for how dowe make a comparison to say, say
somebody wanted to open abusiness, and I'll I'll kinda
let you decide whether it's a aa grower or a provisioning
center or retail versus, youknow, the the similar process
that you wanted to start a,landscaping company or
something?
Just so we could really lay itout for our audience where some
(14:20):
of those kind of paths veer indifferent directions, if that's
okay.
Kareyna Miller (14:24):
Sure. So so to operate a cannabis business, in
any state, the the state itselfwill have its own regulations.
So you have to have a licensethrough the state. Getting that
license, your your facility hasto be compliant. So there's
rules, you know, for forbuilding out your facility,
whether you're a a grower or aretailer.
(14:49):
There's municipal regulations.So here in Michigan, for
example, we have municipalitieswho opt in or opt out, and then
they have their own set ofrules. So you have to be
familiar with the state and withthe local rules of of where
you're operating. You know, it'snot it's not something you can
(15:10):
just say I'm gonna start oneday. It it does require, you
know, pretty intensive capitalin most cases to get started,
especially on the grow and theprocessing side.
You you know, they have a lot ofequipment and in, build outs.
You know, a lot a lot of whatI've seen is, you know, where
the municipalities regulatethese businesses, they're
(15:33):
they're often in industrialareas. So if if you've got a
building that is an oldindustrial facility, there
there's usually substantialimprovements that need to be
made to that building just toget it up to to compliance
specifications. You know, youhave to be careful for,
contaminants, you know, molds,pests, you know, all all these
(15:56):
things that you you don't reallythink about as much or or even
have to think about for atraditional business that that
you do have to take intoconsideration for cannabis.
Chris Picciurro (16:08):
And you mentioned so let let's let's
pivot now because you didmention facility, which is a
great segue to this. Although Ido have one question, so I'm not
pivoting yet, I guess.Interesting. Now when you you
mentioned accrual based, doesthat the inventory has to be
accrual based, or does theentire entity be have to be
taxed as accrual based?
Kareyna Miller (16:27):
Off inventory has to be accrual based. See, it
is So I thought capitalizingcosts.
Chris Picciurro (16:32):
Yes. Yep. Yeah. And are the so are are any of
anyone in the cannabis industryeligible for I know they can't
get a lot of deductions. Are anyof them eligible for any tax
credits, or would probably notThat I'm missing
Kareyna Miller (16:45):
Well, that that's actually a great
question. I I know a number of,cannabis companies who did
receive the employee retentioncredit, because that was based
off of of payroll taxes.
Chris Picciurro (16:56):
Right.
Kareyna Miller (16:57):
Now, you know, you had different opinions.
Could that have been disallowed?Could could that have be one of
these that the IRS isscrutinizing hard? So you really
have to weigh the you know, whatthe risks are in in that. But,
otherwise, if it's income taxrelated, no.
They're not allowed credits oror deductions because of 280 e.
Chris Picciurro (17:19):
I was thinking about, like, research and
development credit. That's theonly that's the only one I was
thinking of. But, you know, sohopefully hopefully for those
taxpayers and for their sakethat this it can get rescheduled
to get in we'll see whathappens. And so segueing into
let's say somebody has a has aowns a owns a warehouse. Right?
(17:40):
And and they get approached bysomeone in the cannabis
industry, and they say, hey. I'dlike to rent this warehouse out.
Obviously, we know with thecannabis industry, there are
some challenges with paymentprocessing, with banking. I
think we've come a long way withsome credit unions and some
outfits being able to being opento doing business. But for
someone that's doing businesswith someone in the cannabis
(18:01):
industry, like a landlord or ormaybe a, I mean, a waste
management company.
Right? Or some some just anormal normal vendors that we
all use operating in office. Arethere any considerations that
those people might might havethey could think of? Or
Kareyna Miller (18:16):
There there is. You know, the the banks want to
know that what they they tend tocall you a tier 2 or tier 3. So
tier 1 is a cannabis operatordirectly. Tier 2, would be
somebody like me who's gettingpayments. Tier 3 is who I'm
paying.
And that depends on the bank andtheir their risk structure.
(18:40):
There at least in Michigan and Iand I know other states that
there are a number of banks andand credit unions, especially,
who are open to working with theindustry. You know, the the cost
is more. So an operator, youknow, I I've seen fees range,
you know, close to $3,000 justto to go through the application
process to open an account. Andthen they're charged, you know,
(19:03):
250 to to a $1,000 per month.
As a tier 2, when I first got inhere, my charge was $50 per
month. I I was able to find abank that that didn't charge for
for tier 2 other than just theirnormal fees. So you do have to
do your research and, you know,find the right banking partner.
Chris Picciurro (19:24):
Right. So if you're someone that's that is a
vendor, a common vendor of a acannabis industry, that that's
something that you need toconsider as well. So, that's a
great, really
John Tripolsky (19:32):
good question. I've never thought about that.
Even like it's, yeah. So, yeah,would would make sense, and I
guess you have to disclose that.Right?
And then, Karina, have you everseen it where I mean, I I don't
know if this really would'vetrickled to you or not. You
know, I'm sure. But I'm alsosure, like, your relationship
with your clients. Right? You'rea you're a a very, very, very
(19:54):
trusted asset to their success.
Right? Like, I'm sure you walkinto some of their facilities
and they got, you know, cookiesand charcuterie board spreads
for you, keeping you happy, withsome warm fuzzy slippers and a
blanket. But have you ever seenit where, say your client is a
tier 1, and then all of asudden, a lot of tier 2 issues
(20:18):
pop up where I don't know if,you know, are are are those tier
I love that they're tier onesand tier twos. It reminds me of
automotive a little bit, but,like, what what happens at that
point? I mean, do you is therean audit process that sometimes
takes place, and, you know, howdoes that look?
Are the outcomes usually neverin the favor of the businesses
tier 1 or 2? And the reason whyI asked that is sometimes, I'm
(20:39):
sure if it goes down all the wayto tier 3, some of these vendors
might not even know that they'redirectly working in the
industry. They might just lookat it as you know, because
there's so many names, right,for companies now. You might not
know what industry they are.Like, Chris, you mentioned if
you're picking up, you know,trash like waste management, do
you really know what industry itis?
Maybe not. Right? Like like,what has been your experience
(21:01):
with that?
Kareyna Miller (21:02):
I and I will I will clarify the tier 3. I I
think it it does depend on howmuch of your mix is from the
industry, how much of yourbusiness. Tier 3 in my mind too
is also so if you have, let'ssay, an investment company at
the top and then you've got, thereal estate company and the,
equipment rental company, andthen those the real estate and
(21:25):
the equipment company arerenting to the cannabis
operator. So money tier 1,cannabis operator up to the
rental company, which is tier 2,and then tier 3 up to the
investor company. That thatGotcha.
I was thinking that too. So thatthat's that's common, you know,
where you have an investorholding company that is they're
(21:46):
there because they're there tofund the business and, you know,
it's ancillary operations. Yeah.As far as what happens, you
know, if if the bank isn'taware, you know, year years ago
when I first got into this, I Iworked with my normal bank and
didn't think anything of it. Andthey found out I was receiving
(22:07):
payments from cannabis companiesand they closed my accounts.
So you you do wanna make surethe bank is aware of what you're
doing and and has thatstructure.
Chris Picciurro (22:16):
Well, that's a great example. I mean, it's not
like you're trying to bemalicious or anything. You just
we, you know, we we don't we raninto that with, we used to have
a niche in helping foreignnationals or non US residents
with, with tax tax compliance,and we had a bank not not like
that. Not on it because, youknow, we were wiring, getting
(22:39):
receiving payments from certaincountries that they didn't like,
you know, and and that that canhappen. So no.
So I wanna wrap up. I was justthinking about because it's the
bigger scope of this. Like,think about, like, payroll for
instance. Do most of thecannabis industry companies are
they are they, able now to dosome type of electric pay
payroll processing? Because Ithink about all and all the
(23:01):
people that even work in acannabis industry, do do they
get a normal w two and can in intheir tax reporting and that
sort of stuff.
So
Kareyna Miller (23:09):
Yep. They they do. There there are a number of
payroll companies that supportthe industry now. Gusto, Gusto,
however you say that. They'reactive in the industry.
That's a pretty common onethat's out there. You know,
there's there's several who whoprovide, what they do though is
they'll they'll put you on thehighest tier because of their
(23:30):
compliance costs. So so there ismore cost to it. Where an issue
is is like 401 k plans for youremployees. I I don't see any of
those.
I mean, that that's kind of a adifferent a different animal.
Health care, they are able toget health care and and benefits
like that, but it's it's morethe investment side that is not
(23:53):
friendly to the industry at all.
Chris Picciurro (23:55):
Wow. Yeah. I mean, I think I I can see that
and, I know, what's, you knowbut think about where it's come.
I mean, when and you said youhow far it's come in the last 5
years, right, as far as thechallenges you had 5 years ago?
Sure.
There are challenges now, but,hopefully, they're they're
different challenges. They're alittle easier to jump those
hurdles and and become more mainstream. So, anything fine
John Tripolsky (24:18):
with your from bags of bills in back alleys.
Yep. Right?
Chris Picciurro (24:24):
So I know we talked a little bit about
Michigan, but any you know,what's your best advice for
someone that doesn't live inMichigan? They're listening in
another state. Yeah. How couldthey find someone, to help them
out on the tax side of thingsand and or just learn about the
rules specifically for that forthat state?
Kareyna Miller (24:43):
Sure. So I would first start with researching the
state's website or or, you know,they they should have a page
with information. Michigan,there's a wealth of information
out there. The they doeducational sessions, on a
regular basis. So so webinarswhere they're teaching about
different topics related tolicensing.
(25:05):
So so that's that's the firstplace to start is with the
state's website. Second place,you know, I would see if if your
your state CPA association hashas any resources. So, like,
here in in Michigan, we have acannabis resource group. We have
a a site with some basicinformation about understanding
(25:27):
the tax rules, you know,understanding some of the
different nuances in theindustry. And it's it's designed
to give enough information whereyou you know what steps to take
to research further.
3rd tip, you know, if you'rebrand new, look look on social
media for different groups. So,you know, again, Michigan, we we
have an active, cannabisprofessionals group with, you
(25:52):
know, I think close to 10,000members in it and people from
other states as well. So if youcan find, you know, resources
like that and throw yourquestions out, ask for a
recommendation for for a taxprofessional who can help, and
you're gonna get that thatfeedback and information back.
John Tripolsky (26:10):
So awesome. And and, Corina, we'll drop your
contact as well in the, in theshow notes and whatnot where
anybody's listening to this too.So if anybody has direct
questions, they can always reachout to you. And unless they're
so busy helping everybody outthere that you'll have to send
them somewhere. But I know wemet you at a at a conference,
you know, Chris and myself, Ibelieve it was last year.
Well, really, it was that longago. If we say last year, 24,
(26:33):
but a while back. And, I mean,honestly, I I was just blown
away with your your knowledge inthat industry, and it seems like
a lot of tax professionals just,I wouldn't say, shy away from
it, but that's just not theircomfort zone. You know? It's a
it's a nontraditional industry.
And, I mean, I appreciated thepresentation that you had and
just walking through it and theway that you explain things to
(26:56):
people. Their questions, Ithink, somebody had in there,
it's you did a really good job.So, basically, what I'm going
around the circles of saying isit's always nice talking to you
about this and hearing kindayour your take on it. And you've
been doing it for a while too.It's not like you just woke up
last Tuesday and thought theindustry would be fun.
Right? It seems like it's youryour niche and passion, so we
(27:16):
appreciate it.
Kareyna Miller (27:17):
Yeah. I I appreciate that. I I do love to
talk about it, so I am happy toanswer any questions.
John Tripolsky (27:24):
Awesome. Awesome. Well, Chris, I don't
know if you have any otherquestions. If not, maybe we'll,
let Karina get back to workbecause I'm sure she's slammed
as well.
Chris Picciurro (27:33):
Absolutely. No. I appreciate her time. Again,
she's an amazing resource. Ifyou have any questions, please
reach out to her if you or reachout to us.
We'll guide you in the rightdirection. Thank you so much.
And and as always, I learn a lotof stuff, so I like that. Yeah.
That's good.
John Tripolsky (27:48):
And that's saying a lot because Chris knows
a lot. So it's Oh
Chris Picciurro (27:51):
my goodness.
John Tripolsky (27:52):
I'll put about a little bit of a better stuff.
But, yeah, Krita, thank you forjoining us. Chris, thanks for
joining your own show again asalways, and we'll see everybody
back here again next week on thepodcast. Different topic,
somewhat different day, somewhatdifferent time. So we'll see
everybody very soon.
Disclaimer (28:08):
The content provided is for educational purposes
only. We encourage you to seekpersonalized investment advice
from your financialprofessional. For all tax and
legal advice, please consultyour CPA or attorney. Investment
advisory services are offeredthrough cabin advisors, a
registered investment advisor.Securities are offered through
cabin securities, a registeredbroker dealer.
The content of this podcast doesnot constitute an offer of
(28:30):
securities. Offerings can onlybe made through an offering
memorandum, and you shouldcarefully examine the risk
factors and other informationcontained in the memorandum.
Hey, everyone, and welcome back to the Teaching Tax
Flow podcast episode 118 today.We're gonna look at cannabis and
taxes, what it means for theindustry, hopefully take some of
the confusion or interest thatyou have and make some sense of
it here with a great guest wehave coming up. But before we do
that, let's take a brief momentand thank our episode sponsor.
Ad Read (00:27):
This podcast is sponsored by Reps Tracker. Are
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yet, click on the link below in this episode's show
notes to go directly to therep's tracker sign up page.
John Tripolsky (00:59):
Alright, everybody. Welcome back to the
Teaching Tax Flow podcast. Asyou heard in the intro or read
in the show description, today,we're gonna talk about something
pretty unique that you may nothave expected from us. So,
obviously, we're gonna dive intothe world of cannabis. Not the
details of the industryspecifically, but how it relates
(01:19):
to taxes.
So if it's something that youhaven't thought thought about,
whether you're in the industry,thinking about going into the
industry, you're thinking aboutinvesting in the industry,
you're a user, you're not auser, etcetera. Just even based
off any interests, this is agood one to listen to because
you might start to connect somedots, if we will, just how some
(01:41):
specific industries do pose somechallenges and opportunities
when it comes to taxes. So asalways, we brought not only this
guy that if you're watching, youcan see, but we brought on a
great guest, which I'll letintroduce here shortly. But,
Chris, you know, as I alwayssay, welcome back to your own
show, sir. How's it going?
Chris Picciurro (01:58):
Thanks, John. Oh, jeez. It's so great to see
you again, John.
John Tripolsky (02:01):
Oh, I know. Look at that.
Chris Picciurro (02:02):
There was
John Tripolsky (02:03):
I am unblushing again. Here I am unblushing.
Chris Picciurro (02:05):
I know. I know. No. It's great to be be back.
I'm excited about this topic.
This is a topic you might thinkto yourself, well, cannabis
industry, that's not a well,this is yeah. How many people
does that affect? Ultimately, itaffects anyone that operates or
works in that industry. So we'regonna talk about owners of some
of businesses in that industry.We're gonna talk about employees
(02:25):
of of in that industry.
We're also gonna talk aboutvendors. So, you know, what
happens if you own a piece ofproperty and you rent it out to
someone in the cannabisindustry? Does that is there a
play role? And then and then,talk through this on a federal
level. We know that each eachstate's a little bit different,
but we could touch on that.
We have an amazing guest, so I'mgonna be quiet. Bringing in
(02:46):
Karina Miller, a CPA based outof Michigan, and we've met many
years ago with through theMichigan Association of CPAs.
She, in my opinion, is theauthority on cannabis industry
tax and actually accounting,attestation, which we'll touch
on a little bit. Karina, welcometo the Teaching Tax Flow
podcast.
Kareyna Miller (03:06):
Thank you, Chris. I'm excited to be here.
Chris Picciurro (03:09):
Can you tell us about yourself and and what how
you know, what led you to becomea a CPA and then ultimately
niche into this industry?
Kareyna Miller (03:18):
Sure. So I I started in the cannabis industry
in in late 2016, so it's it'sbeen a little while now. I got
my CPA license, 2011, so 5 yearsearlier. I went it was a
college. I had a professor who,you know, it was, between
finance and accounting, and, youknow, the their encouragement
(03:40):
was to go into the accountingfield.
So that's what I did, and then,got my start with a a regional
firm here. You know, was therefor, enough time to get my CPA
and to, you know, to see to seehow things worked, and then I I
ended up going into privateindustry, and then into cannabis
after that.
Chris Picciurro (04:03):
Awesome. And and tell us about kind of the
the type of clients youtypically work with, both on a
maybe a tax compliance side, butalso a little bit about, you
know, accounting, attestation. Iknow I'm using the term
attestation. Many of you don'tyou're kinda looking your at
your phone or your computer orwhatever right now saying, why
is this got what is attestation?But we're gonna create a break
(04:23):
that down in a little simplerterms.
Kareyna Miller (04:26):
Sure. Sure. So, two sides to it. So there's, I
have my my core client group whoI I like to call them managed
advisory services. It's it'soverseeing their accounting,
their tax advisory, their taxpreparation, kind of everything
that they need.
I work with small businesses,mostly based in Michigan,
(04:49):
primarily growers andprocessors, and then, a few
retailers as well. Theattestation side is different.
So so attestation, the the CPAhas to be independent. The way I
explained that to a client isthey they don't do anything with
your books. They're not, youknow, helping you with with the
(05:09):
details of your tax planning,your advisory.
There there's somebody probablythat you've never met or or
know, you know, haven't workedwith, you know, somebody,
completely unbiased to yourbusiness. And then they come in,
you know, and and do, anattestation looking over your
your records and making surethey're compliant. So you need
(05:32):
somebody who who isn'toverseeing those to to be able
to attest to them.
Chris Picciurro (05:37):
And so a lot of people and I know you're
specifically in Michigan. Solet's just talk about the
Michigan rules and and eachstate's different. But it's
similar if you're listening,similar to a lot of contractors.
So a lot of contractors need aCPA to come in and kinda put
their their eyes on on yourfinancial statements. And
depending on the size in thecontractors, view, depending on
(06:00):
the size of the entity and thatsort of things, it'll dictate
how much the CPA has to leaninto the financials and how much
time they're putting into it andand testing that they are
accurate.
Can you kind of tell us on afrom a 30,000 folk view in in
the state of Michigan becausethere's a lot of regulation in
this industry. What are some ofthe requirements for someone in
this industry?
Kareyna Miller (06:21):
So Michigan, operators are required to have
an attestation every 3 years,and the the state, puts a a form
together with, it's a set ofagreed upon procedures. So it's,
procedures that the CPA isperforming to to look at your
records to make sure they'recompliant. You know, high level
(06:44):
view, you need to make sure thatyou have all the receipts for
your transaction. So it's a ruleto have and keep your vendor
receipts. So even if it's, youknow, going out for lunch or the
gas station, you know, the therole is to have your receipts.
So even those types oftransactions can be looked at.
Chris Picciurro (07:03):
Awesome. And and if when should someone let's
say you're in this industry as aas a retail person, a processor,
or a grower. When should theystart establishing a
relationship with the CPA in inin building their team out? You
know, CPA bookkeeper, I know youyou have a a great suite of
services that you could provide,but not all CPAs or necessarily
(07:25):
are going to or enrolled agentsfor that matter, do the
bookkeeping in the payroll. Butwhen should they start looking
for that that that firm or thatperson to help them out with it?
Kareyna Miller (07:37):
I I would say at the beginning. So I I think a
lot of clients defer to workingwith an attorney as their first
professional service provider,and they're helping them with
with lease agreements, operatingagreements that have tax matter
sections. And a lot of times Isee a client won't engage a CPA
until long after these types ofagreements to to get their
(08:01):
business started are signed, andand they don't realize exactly
what those agreements mean froma from a tax perspective. So,
you know, do you, for myself, Itend to answer questions. You
know, if somebody called me andsaid, I'm I'm looking at getting
into cannabis.
You know? Can you talk with mefor a few minutes? I I usually
(08:21):
give give some advice. You know,I I don't, you know, I I try to
help. So I would say at leasttry to talk with the CPA in the
beginning.
May maybe you're not, you know,consulting with them on a formal
hourly basis, but at least atleast have that opinion next to
to your, you know, theagreements and things that
you're looking at to get yourbusiness started.
Chris Picciurro (08:43):
And no. That's that's a great advice, and I
think it that transcends a lotof different industries. We see
sometimes people probably betteroff looking for professional
advice, early than too late.And, so if someone is coming so
what are some of the unique taxrules related to the cannabis
industry and in some of therecent potential developments
(09:05):
going on, and then we'll starttalking about some of the other
segments. But specifically rightnow for someone that is
operating a cannabis basedindustry, what yeah.
What are some of the unique taxrules? And and, again, is there
anything coming down thepipeline potentially to change
that?
Kareyna Miller (09:21):
Sure. So the most unique tax rule is, you
know, businesses that are arecannabis. Cannabis is a schedule
1 controlled substance at at thefederal level. So they're
subject to a a tax rule called,280 e, which disallows them from
taking ordinary necessarybusiness expenses. So if you if
(09:42):
you think about, you know, thosetypes of expenses, marketing,
payroll, in some cases, youknow, you're limited, pretty
heavily.
Now from an operator perspectiveand from a a tax professional
perspective, you you are allowedto take your cost of goods sold.
So so to me, that's where thethe fun part kinda comes in,
(10:03):
especially if you are a a groweror processor. You know, there's
there's a specific inventoryregulation that that lists all
the all the costs, you know,that that can be included in
your inventory. So just spendingthe time with the client early
on to get their their accountingchart of accounts set up right
to capture all these costs. Youknow, you're going on the
(10:27):
accrual method of accounting.
So this isn't cash based for forthese operators unless they make
a change of accounting methodelection. So so you have some
complexities there to, you know,make sure you're capturing those
costs and then make sure you'reyou're writing them off properly
as your inventory product issold. Operators, you know, I I
(10:50):
would say, you know, especiallyif you're a grower or processor,
make make sure your CPAunderstands those inventory
regulations because there'sthere's a lot of opportunity for
capturing costs. And if the CPAisn't familiar with that,
they're they're likely to missthings, you know, for you.
Chris Picciurro (11:10):
No. Absolutely. So for for most taxpayers, the
cost of goods sold is for a lotof people with inventory, that's
one of their largest deductions,maybe their largest deduction.
And then, however, they'rethey're able to deduct all other
ordinary necessary businessexpenses. For someone in this
industry right now, they canonly deduct the cost of goods
sold.
But like Karina said, you'vewe're working with the right CPA
(11:31):
firm, right tax professionalthat really understands the
rules. They're gonna be able topotentially capture other
deductions that could beconsidered cost of goods sold,
and offset your taxable income.Because when you're paying tax
on your your income minus costto get sold and not your other
expenses, it gets really, reallyexpensive. So, and and that is
based on the, the Department ofJustice, how they classify
(11:56):
cannabis at this point, Ibelieve. But there is a
potential of reclassification.
I know we're at at the time ofthis recording, that those
proceedings were kicked down theroad a little bit. But if if if
it's a is it a schedule 1 andthey're thinking about moving it
to a schedule 3, or am I,trusting my memory too much?
Kareyna Miller (12:17):
That's correct. The the department of, human
health services recommended,moving cannabis to schedule 3.
Now then this was back,springtime of last year. So the,
they they went through a commentperiod session over this. They
had a hearing, on December 2nd,so so little over a month ago at
(12:40):
the time of this recording.
But they didn't have expertwitness testimony there, so they
couldn't complete the hearingprocedures and then pushed it
off. So so there is potential,you know, if it was rescheduled
to schedule 3, you know, youhave the where 280 e only
applies to schedule 1 andschedule 2. But then you get
(13:01):
into, you you know, schedule 3.And and if my memory is serving
me right, that's the sameschedule as, you know, codeine
and and other types ofpharmaceuticals like that. And
there there's no adult use,recreational use for for
pharmaceutical.
Chris Picciurro (13:18):
Right.
Kareyna Miller (13:18):
You know? So so there there's still some
regulatory, you know, issuesthey're gonna have to work out
if if they do, push it toschedule 3.
Chris Picciurro (13:28):
Well, Karina, they they should have gotten
your number for experttestimony. So shame on them for
not using the resources teachingtax law has. That's what I have
to say. Right.
John Tripolsky (13:36):
So, Karina, a couple of questions for you too.
So, you know, I'm I'm gonna makethe assumption that majority of
our audience that's listening tothis probably isn't in the
industry. Again, depending ontheir geographic location,
they're probably surrounded bythe industry one way, shape, or
form. And then, you know,obviously, there's a lot of
interest that goes around this.So I don't know the best way to
(13:57):
really ask as far as for how dowe make a comparison to say, say
somebody wanted to open abusiness, and I'll I'll kinda
let you decide whether it's a aa grower or a provisioning
center or retail versus, youknow, the the similar process
that you wanted to start a,landscaping company or
something?
Just so we could really lay itout for our audience where some
(14:20):
of those kind of paths veer indifferent directions, if that's
okay.
Kareyna Miller (14:24):
Sure. So so to operate a cannabis business, in
any state, the the state itselfwill have its own regulations.
So you have to have a licensethrough the state. Getting that
license, your your facility hasto be compliant. So there's
rules, you know, for forbuilding out your facility,
whether you're a a grower or aretailer.
(14:49):
There's municipal regulations.So here in Michigan, for
example, we have municipalitieswho opt in or opt out, and then
they have their own set ofrules. So you have to be
familiar with the state and withthe local rules of of where
you're operating. You know, it'snot it's not something you can
(15:10):
just say I'm gonna start oneday. It it does require, you
know, pretty intensive capitalin most cases to get started,
especially on the grow and theprocessing side.
You you know, they have a lot ofequipment and in, build outs.
You know, a lot a lot of whatI've seen is, you know, where
the municipalities regulatethese businesses, they're
(15:33):
they're often in industrialareas. So if if you've got a
building that is an oldindustrial facility, there
there's usually substantialimprovements that need to be
made to that building just toget it up to to compliance
specifications. You know, youhave to be careful for,
contaminants, you know, molds,pests, you know, all all these
(15:56):
things that you you don't reallythink about as much or or even
have to think about for atraditional business that that
you do have to take intoconsideration for cannabis.
Chris Picciurro (16:08):
And you mentioned so let let's let's
pivot now because you didmention facility, which is a
great segue to this. Although Ido have one question, so I'm not
pivoting yet, I guess.Interesting. Now when you you
mentioned accrual based, doesthat the inventory has to be
accrual based, or does theentire entity be have to be
taxed as accrual based?
Kareyna Miller (16:27):
Off inventory has to be accrual based. See, it
is So I thought capitalizingcosts.
Chris Picciurro (16:32):
Yes. Yep. Yeah. And are the so are are any of
anyone in the cannabis industryeligible for I know they can't
get a lot of deductions. Are anyof them eligible for any tax
credits, or would probably notThat I'm missing
Kareyna Miller (16:45):
Well, that that's actually a great
question. I I know a number of,cannabis companies who did
receive the employee retentioncredit, because that was based
off of of payroll taxes.
Chris Picciurro (16:56):
Right.
Kareyna Miller (16:57):
Now, you know, you had different opinions.
Could that have been disallowed?Could could that have be one of
these that the IRS isscrutinizing hard? So you really
have to weigh the you know, whatthe risks are in in that. But,
otherwise, if it's income taxrelated, no.
They're not allowed credits oror deductions because of 280 e.
Chris Picciurro (17:19):
I was thinking about, like, research and
development credit. That's theonly that's the only one I was
thinking of. But, you know, sohopefully hopefully for those
taxpayers and for their sakethat this it can get rescheduled
to get in we'll see whathappens. And so segueing into
let's say somebody has a has aowns a owns a warehouse. Right?
(17:40):
And and they get approached bysomeone in the cannabis
industry, and they say, hey. I'dlike to rent this warehouse out.
Obviously, we know with thecannabis industry, there are
some challenges with paymentprocessing, with banking. I
think we've come a long way withsome credit unions and some
outfits being able to being opento doing business. But for
someone that's doing businesswith someone in the cannabis
(18:01):
industry, like a landlord or ormaybe a, I mean, a waste
management company.
Right? Or some some just anormal normal vendors that we
all use operating in office. Arethere any considerations that
those people might might havethey could think of? Or
Kareyna Miller (18:16):
There there is. You know, the the banks want to
know that what they they tend tocall you a tier 2 or tier 3. So
tier 1 is a cannabis operatordirectly. Tier 2, would be
somebody like me who's gettingpayments. Tier 3 is who I'm
paying.
And that depends on the bank andtheir their risk structure.
(18:40):
There at least in Michigan and Iand I know other states that
there are a number of banks andand credit unions, especially,
who are open to working with theindustry. You know, the the cost
is more. So an operator, youknow, I I've seen fees range,
you know, close to $3,000 justto to go through the application
process to open an account. Andthen they're charged, you know,
(19:03):
250 to to a $1,000 per month.
As a tier 2, when I first got inhere, my charge was $50 per
month. I I was able to find abank that that didn't charge for
for tier 2 other than just theirnormal fees. So you do have to
do your research and, you know,find the right banking partner.
Chris Picciurro (19:24):
Right. So if you're someone that's that is a
vendor, a common vendor of a acannabis industry, that that's
something that you need toconsider as well. So, that's a
great, really
John Tripolsky (19:32):
good question. I've never thought about that.
Even like it's, yeah. So, yeah,would would make sense, and I
guess you have to disclose that.Right?
And then, Karina, have you everseen it where I mean, I I don't
know if this really would'vetrickled to you or not. You
know, I'm sure. But I'm alsosure, like, your relationship
with your clients. Right? You'rea you're a a very, very, very
(19:54):
trusted asset to their success.
Right? Like, I'm sure you walkinto some of their facilities
and they got, you know, cookiesand charcuterie board spreads
for you, keeping you happy, withsome warm fuzzy slippers and a
blanket. But have you ever seenit where, say your client is a
tier 1, and then all of asudden, a lot of tier 2 issues
(20:18):
pop up where I don't know if,you know, are are are those tier
I love that they're tier onesand tier twos. It reminds me of
automotive a little bit, but,like, what what happens at that
point? I mean, do you is therean audit process that sometimes
takes place, and, you know, howdoes that look?
Are the outcomes usually neverin the favor of the businesses
tier 1 or 2? And the reason whyI asked that is sometimes, I'm
(20:39):
sure if it goes down all the wayto tier 3, some of these vendors
might not even know that they'redirectly working in the
industry. They might just lookat it as you know, because
there's so many names, right,for companies now. You might not
know what industry they are.Like, Chris, you mentioned if
you're picking up, you know,trash like waste management, do
you really know what industry itis?
Maybe not. Right? Like like,what has been your experience
(21:01):
with that?
Kareyna Miller (21:02):
I and I will I will clarify the tier 3. I I
think it it does depend on howmuch of your mix is from the
industry, how much of yourbusiness. Tier 3 in my mind too
is also so if you have, let'ssay, an investment company at
the top and then you've got, thereal estate company and the,
equipment rental company, andthen those the real estate and
(21:25):
the equipment company arerenting to the cannabis
operator. So money tier 1,cannabis operator up to the
rental company, which is tier 2,and then tier 3 up to the
investor company. That thatGotcha.
I was thinking that too. So thatthat's that's common, you know,
where you have an investorholding company that is they're
(21:46):
there because they're there tofund the business and, you know,
it's ancillary operations. Yeah.As far as what happens, you
know, if if the bank isn'taware, you know, year years ago
when I first got into this, I Iworked with my normal bank and
didn't think anything of it. Andthey found out I was receiving
(22:07):
payments from cannabis companiesand they closed my accounts.
So you you do wanna make surethe bank is aware of what you're
doing and and has thatstructure.
Chris Picciurro (22:16):
Well, that's a great example. I mean, it's not
like you're trying to bemalicious or anything. You just
we, you know, we we don't we raninto that with, we used to have
a niche in helping foreignnationals or non US residents
with, with tax tax compliance,and we had a bank not not like
that. Not on it because, youknow, we were wiring, getting
(22:39):
receiving payments from certaincountries that they didn't like,
you know, and and that that canhappen. So no.
So I wanna wrap up. I was justthinking about because it's the
bigger scope of this. Like,think about, like, payroll for
instance. Do most of thecannabis industry companies are
they are they, able now to dosome type of electric pay
payroll processing? Because Ithink about all and all the
(23:01):
people that even work in acannabis industry, do do they
get a normal w two and can in intheir tax reporting and that
sort of stuff.
So
Kareyna Miller (23:09):
Yep. They they do. There there are a number of
payroll companies that supportthe industry now. Gusto, Gusto,
however you say that. They'reactive in the industry.
That's a pretty common onethat's out there. You know,
there's there's several who whoprovide, what they do though is
they'll they'll put you on thehighest tier because of their
(23:30):
compliance costs. So so there ismore cost to it. Where an issue
is is like 401 k plans for youremployees. I I don't see any of
those.
I mean, that that's kind of a adifferent a different animal.
Health care, they are able toget health care and and benefits
like that, but it's it's morethe investment side that is not
(23:53):
friendly to the industry at all.
Chris Picciurro (23:55):
Wow. Yeah. I mean, I think I I can see that
and, I know, what's, you knowbut think about where it's come.
I mean, when and you said youhow far it's come in the last 5
years, right, as far as thechallenges you had 5 years ago?
Sure.
There are challenges now, but,hopefully, they're they're
different challenges. They're alittle easier to jump those
hurdles and and become more mainstream. So, anything fine
John Tripolsky (24:18):
with your from bags of bills in back alleys.
Yep. Right?
Chris Picciurro (24:24):
So I know we talked a little bit about
Michigan, but any you know,what's your best advice for
someone that doesn't live inMichigan? They're listening in
another state. Yeah. How couldthey find someone, to help them
out on the tax side of thingsand and or just learn about the
rules specifically for that forthat state?
Kareyna Miller (24:43):
Sure. So I would first start with researching the
state's website or or, you know,they they should have a page
with information. Michigan,there's a wealth of information
out there. The they doeducational sessions, on a
regular basis. So so webinarswhere they're teaching about
different topics related tolicensing.
(25:05):
So so that's that's the firstplace to start is with the
state's website. Second place,you know, I would see if if your
your state CPA association hashas any resources. So, like,
here in in Michigan, we have acannabis resource group. We have
a a site with some basicinformation about understanding
(25:27):
the tax rules, you know,understanding some of the
different nuances in theindustry. And it's it's designed
to give enough information whereyou you know what steps to take
to research further.
3rd tip, you know, if you'rebrand new, look look on social
media for different groups. So,you know, again, Michigan, we we
have an active, cannabisprofessionals group with, you
(25:52):
know, I think close to 10,000members in it and people from
other states as well. So if youcan find, you know, resources
like that and throw yourquestions out, ask for a
recommendation for for a taxprofessional who can help, and
you're gonna get that thatfeedback and information back.
John Tripolsky (26:10):
So awesome. And and, Corina, we'll drop your
contact as well in the, in theshow notes and whatnot where
anybody's listening to this too.So if anybody has direct
questions, they can always reachout to you. And unless they're
so busy helping everybody outthere that you'll have to send
them somewhere. But I know wemet you at a at a conference,
you know, Chris and myself, Ibelieve it was last year.
Well, really, it was that longago. If we say last year, 24,
(26:33):
but a while back. And, I mean,honestly, I I was just blown
away with your your knowledge inthat industry, and it seems like
a lot of tax professionals just,I wouldn't say, shy away from
it, but that's just not theircomfort zone. You know? It's a
it's a nontraditional industry.
And, I mean, I appreciated thepresentation that you had and
just walking through it and theway that you explain things to
(26:56):
people. Their questions, Ithink, somebody had in there,
it's you did a really good job.So, basically, what I'm going
around the circles of saying isit's always nice talking to you
about this and hearing kindayour your take on it. And you've
been doing it for a while too.It's not like you just woke up
last Tuesday and thought theindustry would be fun.
Right? It seems like it's youryour niche and passion, so we
(27:16):
appreciate it.
Kareyna Miller (27:17):
Yeah. I I appreciate that. I I do love to
talk about it, so I am happy toanswer any questions.
John Tripolsky (27:24):
Awesome. Awesome. Well, Chris, I don't
know if you have any otherquestions. If not, maybe we'll,
let Karina get back to workbecause I'm sure she's slammed
as well.
Chris Picciurro (27:33):
Absolutely. No. I appreciate her time. Again,
she's an amazing resource. Ifyou have any questions, please
reach out to her if you or reachout to us.
We'll guide you in the rightdirection. Thank you so much.
And and as always, I learn a lotof stuff, so I like that. Yeah.
That's good.
John Tripolsky (27:48):
And that's saying a lot because Chris knows
a lot. So it's Oh
Chris Picciurro (27:51):
my goodness.
John Tripolsky (27:52):
I'll put about a little bit of a better stuff.
But, yeah, Krita, thank you forjoining us. Chris, thanks for
joining your own show again asalways, and we'll see everybody
back here again next week on thepodcast. Different topic,
somewhat different day, somewhatdifferent time. So we'll see
everybody very soon.
Disclaimer (28:08):
The content provided is for educational purposes
only. We encourage you to seekpersonalized investment advice
from your financialprofessional. For all tax and
legal advice, please consultyour CPA or attorney. Investment
advisory services are offeredthrough cabin advisors, a
registered investment advisor.Securities are offered through
cabin securities, a registeredbroker dealer.
The content of this podcast doesnot constitute an offer of
(28:30):
securities. Offerings can onlybe made through an offering
memorandum, and you shouldcarefully examine the risk
factors and other informationcontained in the memorandum.
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