The Spring 2019 unclaimed property reporting season is nearing an end. Michigan and Texas remain the only states with July 31, 2019 filing dates. Most corporate tax and accounting professionals who manage this process can see the light at the end of the tunnel.
Unfortunately, there is little rest time as the Fall 2019 unclaimed property reporting season begins on June 30, 2019. 43 states with fall deadlines use June 30 as their "cut-off date," which is the "as of" date for which a transaction must have been dormant for three or five years to be treated as unclaimed property during the Fall 2019 reporting season. Gathering data that has aged between three and five years from disparate systems is one of the most time consuming and laborious tasks associated with unclaimed property compliance.
Most Fall reporting states call for corporations to begin the process of mailing due diligence owners 120 days before the Fall filing deadlines of October 31, 2019 and November 1, 2019. That date is June 30. The thresholds for due diligence vary amongst Fall reporting states from $25 to $100 dollars, with many using $50 dollars.
In many ways, the Fall unclaimed property reporting season is intense. 11 states have final reporting deadlines on October 31 with California's preliminary reporting deadline sharing that date and 30 states use November 1 as their deadline. In a twist, Tennessee switched from a Spring to Fall state this year, enacting a November 1 deadline in one of the many legislative changes of 2018.
Making the final filings on November 1 is quite an accomplishment. With little uniformity in laws amongst the states, the Fall reporting season is all about juggling various due diligence mailing dates and dollar thresholds as well as competing electronic and paper filing and payment requirements. The only saving grace of Fall reporting is that the filing dates are uniform.
Many corporate tax and accounting professionals are understandably lulled into the false sense that there is a break between the Spring and Fall reporting seasons. The truth is that unclaimed property reporting has become a year-round effort, and in many ways, the Fall season is intensely challenging.
In this light, many corporate tax and accounting professionals will shop for an outsourced unclaimed property solution in June and July. After all, the Spring reporting season is the first experience many have with unclaimed property reporting. They realize that a solution allowing them to do what they do best, and outsource the rest, makes sense based on the hours they spent on Spring reporting.
The Duff & Phelps Unclaimed Property team invites you to contact us to learn more about our cost-effective and highly efficient unclaimed property reporting services. Our clients enjoy comprehensive outsourced unclaimed property support from our state-of-the-art Center of Excellence in Addison, Texas. All services are scalable, allowing clients to retain certain tasks if desired. However, most leverage our full capabilities, including:
- Data extracting and parsing
- Maintained subledger
- Real-time online access to data and metrics reporting via our new proprietary tool Unclaimed Property LINK
- Dormancy and due diligence eligibility analysis with exemption review
- Due diligence mailing and response management
- Report preparation with signature
- Filing and payment remittance
When coupled with our asset recovery services, Duff & Phelps' unclaimed property reporting experts help clients ensure their corporations are fully compliant, while becoming a profit center.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
