Regulatory Analysis

Posted May 11, 2021 by Danielle Herring
Washington Department of Revenue Rolls out New Website

The Washington Department of Revenue has rolled out a new website to make reporting and claiming of property easier. The new website, claimyourcash.org, has features to simplify the claims process: Claims that meet a certain criteria can now be fast tracked and processed within 5 days. The website has a mobile friendly design to make […]

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Posted May 11, 2021 by Danielle Herring
Tennessee Passes Bills to Amend Existing RUUPA Law

Enacted by signature of the Governor and effective April 28, 2021. These are companion bills with identical wording. These bills make changes to the state’s existing law. The bills can be found here. The amendments to the law will change the date used to determine when property held in a pension or retirement account that […]

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Posted May 11, 2021 by Danielle Herring
Indiana Passes Bill to Follow RUUPA

Enacted by signature of the Governor on April 29, 2021 and effective July 1, 2021. Due to the cut-off date for the fall cycle, and the lack of a “transitional provision,” this bill will not change holders’ obligations for reporting in 2021. As previously highlighted, this RUUPA bill will replace the state’s existing law. The […]

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Posted April 23, 2021 by Danielle Herring
ND Passes Bill to Follow RUUPA

ND S 2048: Enacted – Variation of the “Revised Uniform Unclaimed Property Act” Enacted by signature of the Governor on April 19, 2021. The bill enacts RUUPA legislation. The bill is effective August 1, 2021. The changes will impact reporting for 2022. The new law has standard RUUPA provisions with a few exceptions. Dormancy for […]

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Posted April 23, 2021 by Paul Ogawa
Michigan Publishes Interest Rate for the Second Half of 2021

The Michigan Department of Treasury recently published Revenue Administrative Bulletin 2021-5, which details the interest rate for underpayments and over payments for the period beginning on July 1, 2021 to December 31, 2021. The interest rate for this period remains unchanged from the first half of 2021, at an annual rate of 4.25%. To review […]

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Posted April 21, 2021 by Danielle Herring
Delaware S 104: Introduced – Unclaimed Property Audit Practices, VDA’s, IRA’s

Introduced April 14, 2021 this bill, if enacted, would become effective on August 1, 2021; with certain provisions applying retroactively to any claims, examinations, or litigation pending as of the effective date. This proposed bill covers three areas: audit practices, Voluntary Disclosure Agreements (VDA’s) and Individual Retirement Accounts (IRA’s). If passed this bill would expand […]

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Posted April 21, 2021 by Danielle Herring
Delaware S 103: Introduced – Unclaimed Property Virtual Currency

Introduced April 14, 2021 this bill, if enacted, would become effective on August 1, 2021. This bill would add provisions to the Delaware Unclaimed Property Act specifically requiring the reporting and remittance of virtual currency. DE S 103 defines virtual currency as a digital representation of value, including cryptocurrency, that does not have legal tender […]

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Posted April 21, 2021 by Danielle Herring
Colorado S 121: Enacted – Modifications to the “Revised Uniform Unclaimed Property Act”

Enacted and effective by signature of the Governor on April 15, 2021. The bill makes multiple changes to the Revised Uniform Unclaimed Property Act (the “Act”). This bill provides a specific definition of Financial Organization Loyalty Cards and exempts such items from the definition of Property under the Act. CO S 121 also removed two […]

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Posted April 8, 2021 by Sovos
Massachusetts Unclaimed Property Self Review Invitations

MA Self Review Invitation Letters Update: April 2021 Pursuant to The Massachusetts Unclaimed Property Law (M.G.L.c. 200A), the Commonwealth of Massachusetts, State Treasurer’s Office (the “Commonwealth”) issued a wave of letters inviting companies to participate in their Self-Review Program. The Commonwealth mailed notices to holders believed to be noncompliant with Massachusetts unclaimed property reporting laws and […]

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Posted April 8, 2021 by Paul Ogawa
IRS Extends Filing Due Date for 5498 Form Series

The IRS recently published Notice 2021-21 which extends a number of due dates as a form of relief pursuant to 26 U.S.C. 7508A(a). Due to the ongoing COVID-19 emergency the Secretary of Treasury has been granted the authority to provide relief in the form of extended due dates for certain returns and forms, including the […]

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Posted March 25, 2021 by Robert Beck
Virginia Announces Interest Rates for Second Quarter of 2021

Virginia recently announced the interest rates for underpayments and overpayments of tax for the second quarter of 2021. Virginia bases it’s rates on the federal rates, holding their rates at 2% higher than the federal rates for over and underpayments. As the Federal rates for the second quarter have not changed, Virginia will maintain its […]

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Posted March 25, 2021 by Robert Beck
Missouri Adds 1099-NEC information to the Withholding Tax FAQs

Missouri recently added three questions with answers to its Withholding Tax FAQ list. All three questions are regarding the revival of Form 1099-NEC. See the questions below: The first question asked whether the 1099-NEC needed a cover form like the MO-96 covered the 1099-MISC in previous years. The response is that no cover form is […]

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Posted March 25, 2021 by Robert Beck
Delaware Releases Withholding Form W3 Annual Reconciliation Instructions

Delaware recently released a new instruction sheet for Form W3 annual reconciliations. The instruction set gives box by box and line by line instructions on how to complete the W3 annual reconciliation form. In addition to instructions, the sheet gives the reminder that all employers required to file W-2s and 1099s electronically for federal purposes […]

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Posted March 16, 2021 by Katherine Mullen
Maryland Veto Overrides

On February 12, the Maryland Legislature overrode the Governor’s veto of House Bills 932 and 732 of the 2020 legislative session. Under the Maryland constitution, this means that the laws take effect 30 days after the override, or on the date specified in the Bills, whichever is later. As a result, House Bills 932 and […]

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Posted March 16, 2021 by Robert Beck
North Dakota Releases 2021 Income Tax Withholding Guide

North Dakota recently released the 2021 version of it’s Income Tax Withholding Guideline, the employer’s guide to withholding for the state. Few changes were made this year, most of which revolve around the addition of federal Form 1099-NEC. These are detailed below: • Under reportable payments, 1099-NEC reportable payments have been differentiated from 1099-MISC reportable […]

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Posted March 16, 2021 by Paul Ogawa
New York Publishes Updated Electronic Filing Specifications for Quarterly Combined Wage & Withholding Reports

The New York State Department of Taxation and Finance recently published an updated version of Publication 69, Electronic Reporting of Quarterly Combined Wage & Withholding Tax Information. This publication provides guidance and electronic filing specifications for withholding tax information relative to certain wage information to the Department. While the electronic reporting specifications themselves remain unchanged […]

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Posted March 16, 2021 by Paul Ogawa
Iowa Publishes Clarifying Guidance on Due Date for W-2 and 1099 Information Returns

The Iowa Department of Revenue recently published an update to certain Administrative Rules relating to a variety of topics including filing W-2 and 1099 forms. In 2019 the Department of Revenue adopted an amendment to Iowa Administrative Code Chapter 46 that inadvertently moved the annual deadline for filing Verified Summary of Payment (VSP) Reports, W-2 […]

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Posted February 19, 2021 by Sovos
Delaware Voluntary Disclosure (VDA) Invitation Letters

DE VDA Invitation Letters Update: February 19, 2021 Pursuant to 12 Del. C. §1173(b), the Delaware Secretary of State (SOS) has distributed a new wave of letters inviting companies to enter the unclaimed property Voluntary Disclosure Agreement (VDA) Program. Holders have 60 days from the date of the letter to enroll in the SOS VDA […]

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