Uniform Unclaimed Property Act: Before the beginning of November, many businesses are trying to complete their fall filings of accounts and other financial instruments they hold that have gone dormant for a specified period of time, typically three to five years, depending on the state. But there is little uniformity in laws among the different states, so the fall reporting season may involve juggling various due diligence mailing dates and dollar thresholds, along with completing electronic paper filing and payment requirements. There’s a major reporting season coming up, said Scott Regan, a director in the Duff & Phelps Unclaimed Property and Tax Risk Advisory team. The two important dates are October 31 and November 1 according to him. There are fully 40 states that have deadlines on those two dates. The problem is that there’s a real lack of uniformity, and the states all have nuanced requirements that make this a headache for corporate accounting professionals at big companies.
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Another complication is the different dormancy periods for various types of property. That’s the amount of time that a property has to be held before it’s considered to be abandoned and possibly to be reported or remitted to a state, Regan Duff & Phelps director explained. There are different notification requirements, or what we in the business would call due diligence. Some states require certified mailings. Certain states have thresholds of over $50 or over $100. Some states want the letters to go out 120 days before a filing deadline, some of them 60. There’s really just a variety of dates, dormancy periods, deadlines and due diligence requirements. To bring some consistency to the rules, in 2016 a group known as the Uniform Law Commission passed the Revised Uniform Unclaimed Property Act, but many states haven’t been in a hurry to adopt it. The changes under the Revised Uniform Unclaimed Property Act could even lead to some confusion for retailers.
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Source: Accounting Today
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