Adp Totalsource Inc H&W Trust

Schedule D, Part X, Line 2 FIN 48 (ASC 740) footnote

“The Trust established under the Plan to hold the Plan's assets is intended to qualify as a tax-exempt entity pursuant to Section 501(c)(9) of the Internal Revenue Code ("IRC"). The Trust has obtained an exemption letter dated May 28, 2008, and effective January 1, 2007, from the Internal Revenue Service. The Plan sponsor believes that the Trust continues to qualify and operate in accordance with the applicable requirements of the IRC. Any unrelated business income generated by the Trust is subject to tax under the IRC. U.S. GAAP requires plan management to evaluate tax positions taken by the plan and recognize a tax liability (or asset) if the plan has taken an uncertain tax position that more likely than not would be sustained upon examination by the IRS. The plan administrator has analyzed the tax positions taken by the Plan, and has concluded that as of May 31, 2018 and 2017, there are no uncertain tax positions taken or expected to be taken that would require recognition of a liability (or asset) or disclosure in the financial statements. The Plan is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress. The plan administrator believes it is no longer subject to income tax examinations for years prior to 2015. (Note the VEBA trust has a different year end the audited FS year end. )”