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Comments in Response to the Abandoned or Unclaimed Property Reporting and Examination Manual and Voluntary Disclosure Agreement

Altus Group provided written comments to the State of Delaware in response to the proposed regulations impacting the unclaimed property voluntary disclosure program and unclaimed property audits.  These regulations impact companies across the country.  Businesses currently under audit should be aware that once regulations are adopted, they will have 60 days to decide how to move forward with their audit: fast-track the audit, convert to a VDA, or do nothing and be faced with mandatory interest.

Included in the letters are comments on:

  1. Exclusion of payments to a U.S. Federal Dept. or Agency;
  2. Request for attestation of record availability;
  3. Analysis of accounts receivable;
  4. Availability of contracts between the State and third-party audit firms;
  5. Clarification of “day-based” deadlines;
  6. The “two of three data points” requirement for identifying last known addresses;
  7. Records to be retained by the Holder;
  8. Size and industry as a factor for determining which Holders to audit;
  9. Auditor access to Holder’s employees;
  10. Lack of record retention policies applicable to the State;
  11. Definition of “reasonable time frame” for holders to respond to audit requests; and
  12. Explanation for insufficient documentation.

The proposed regulations and the Altus Group comments can be viewed at the links below:

Department of State Voluntary Disclosure Regulations

 

Department of Finance Abandoned or Unclaimed Property Reporting and Examination Manual

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Julia ColbusColbusbu-state-local-tax unclaimed-propertyhunt-valley

Senior Director, State & Local Tax

Last updated on September 4th, 2019 at 04:17 pm

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