Fall 2011 issue of Horizons

Hospitality & Gaming – continued

a member of your club should be recorded as nonmember income. Although many clubs will show a loss related to this activity, due to the available methods of allocating expenses, the issue is important when calculating the 15 percent/35 percent limitation of Rev. Proc. 71-17 . Escheat Laws Is your club holding funds related to stocks, bonds or certificates of resigned members? Depending on your state law, these funds could be considered abandoned, unclaimed property and subject to reporting and remittance requirements. Many states define a period of time after which property is considered “abandoned” and should be remitted to the state for holding until such person files a claim to collect such. Clubs should not intend to hold the funds forever and should comply with the requirements of their state. In some cases, penalties apply for non-filing. Americans With Disabilities Act (ADA) Does your club have single rider golf carts available for mobility-impaired players? If your club is deemed open to the general public, this could be a priority. Clubs considered “bona fide” private clubs that are open to only members and their guests, do not regularly hold public events and are tax-exempt under 501(c)(7) are exempt from ADA regulations. However, if your club has nonmember income, it may be considered open to the general public and excluded from exemption from ADA compliance. Clubs hosting outside tournaments (nonmember income) could be found to place the mobility- impaired at a disadvantage if no single rider golf carts are available. Clubs should consult with their attorney regarding ADA applicability via nonmember usage.

RubinBrown In The Marketplace Congratulations to Victor

Pate, Gaming Inspector of the Chickasaw National Office of the Gaming Commissioner (with RubinBrown’s Daniel Holmes) for winning an Apple iPad at the NIGA Tradeshow

in April. In August at the OIGA tradeshow, RubinBrown presented a Garmin to Marie Moss, Facilities Manager of Creek Nation Casino Muscogee. RubinBrown would like to thank Dominic Ortiz, CFO of the Prairie Band Casino, for his efforts in being a co- presenter during our Casino Budgeting seminar at the 2011 NIGA Conference in Phoenix, Arizona and the OIGA Conference in Tulsa, Oklahoma.

RubinBrown would like to thank Tim Ilsley, Vice President of Internal Audit of Isle of Capri Casinos (with RubinBrown’s Chelle Adams), for his efforts in serving as a co-presenter during the Count Room Frauds seminar at the 2011 IIA Gaming Conference in Las Vegas, Nevada.

In July, RubinBrown participated in the Club Tax Network Providence Summit. This event is held by the Club Tax Network, which is an association of accounting firms, law firms,

and other consultants that serve the private club industry. RubinBrown Manager Jeff Sackman (third from the right of the second row) and his collegues focused this year on eliminating overauditing.

Raise Your Expectations

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