ABC Amega. Unclaimed Property Presentation. Presenters: Michael Kenehan Nick Boegel. April 21, 2016
|
|
- Leo Walters
- 6 years ago
- Views:
Transcription
1 ABC Amega Unclaimed Property Presentation Presenters: Michael Kenehan Nick Boegel April 21, 2016
2 Agenda
3 Agenda 1. Unclaimed Property Overview 2. Extrapolation 3. Audit Process Retail/Service Industry 4. Top 10 UCP Issues with A/R 5. Mitigation Strategies 6. Updates in Industry 7. Questions 8. Bios Page 3
4 Unclaimed Property Overview
5 Unclaimed Property Overview All 50 states and the District of Columbia have enacted unclaimed property laws. The purpose of unclaimed property laws is to ensure the protection of abandoned property until the rightful owner is located. Moreover, states use any derivative funds earned on such property for the public good. States actively pursue unclaimed property as an additional source of revenue, which avoids raising taxes States unclaimed property laws apply to all entity types, including: Corporations S Corporations Partnerships Limited Liability Companies Page 5
6 Unclaimed Property Overview Generally intangible personal property for which there has been no owner activity for a specified period of time ( dormancy period ). Examples of unclaimed property: Uncashed payroll or commission checks Uncashed payable/vendor checks Gift certificates/gift cards Customer merchandise credits, layaways, deposits, refunds or rebates Overpayments/unidentified remittances Unused/outstanding benefits (non-erisa) Miscellaneous income/bad debt expense accounts Page 6
7 Unclaimed Property Overview The Supreme Court of the United States in Texas v. New Jersey, established the following unclaimed property sourcing rule: First, to the state of the rightful owner s last known address, if known, or Second, to the state of the holder s incorporation (commercial domicile for unincorporated entities). Priority rules in Texas v. New Jersey were upheld in the subsequent cases Pennsylvania v. New York (escheat of money orders) and Delaware v. New York (unclaimed dividends and interest). Although not sanctioned by the Court, some states have adopted a transactional or throwback rule, which provides that if both the state of the owner s last known address and the state of the holder s incorporation decline or fail to exercise jurisdiction over the unclaimed property, then the state in which the transactions giving rise to such property occurred has the right to claim the property. Page 7
8 Unclaimed Property Overview Dormancy Periods Dormancy Period : A statutorily prescribed period that begins from the date of creation of the property type (e.g., check issuance date) and ends after the passage of a certain number of years (typically 1-5 years). Property becomes presumed abandoned when it has remained unclaimed during the statutory dormancy period. State Wages (years) A/R Credit Balances (years) Third Party Dividends (years) Gift Cards (years) A/P Checks (years) All other property (years) DE No NY No CA No IL Yes FL No TX Yes (deferral) B2B Page 8
9 Unclaimed Property Extrapolation
10 Extrapolation Many states, including Delaware, use extrapolation techniques to establish a historic liability, at times dating back to 1991, in the event all records requested are not available and/or complete. The determination of whether or not to extrapolate may depend of factors such as: Historical unclaimed property reporting practices Filing history Materiality of errors found for periods where records were reviewed Record availability and reliability by property type Page 10
11 Exposure Quantification: PAYROLL EXTRAPOLATION Unremediated Payroll O/S Checks 12/31/2004 Federal 1120 Payroll 12/31/2004 = % x Federal 1120 Payroll (prior years) Page 11
12 Exposure Quantification: ACCOUNTS PAYABLE EXTRAPOLATION Accounts Payable O/S Checks - 12/31/2004 Federal 1120 Sales 12/31/2004 = % x Federal 1120 Sales (prior years) Page 12
13 Exposure Quantification: ACCOUNTS RECEIVABLE EXTRAPOLATION If all sales are on account, the following extrapolation can be used: Unremediated Net Credits 1 12/31/2004 Sales - 12/31/2004 = % x Sales (prior years) Holder should review credits written off (e.g. to miscellaneous income/expense account) to any amounts of bad debt as this is a viable position to offset net credits that is often overlooked. 1 In many cases the net credits were written off to miscellaneous income, allowance for doubtful accounts, or bad debt expense and documentation to prove it is not escheatable is unavailable. Page 13
14 Exposure Quantification Total Unclaimed Property Liability (ALL STATES) for Base Period (a) Base Period = Total Sales (1120) for Base Period (b) Escheat Percentage (c) (Unclaimed Property Liability(a)/Total Sales (b)) Escheat Percentage(c) * Total Sales in Non-Base Period(d) = Total Projected Liability(e) Projection Years Total Projected Liability(e) + Address Property(f) = Total Liability Owed (Projection and Address) Page 14
15 Example of the Impact of Extrapolation Year Sales Total Unremdiated Unclaimed Property Unremediated Unclaimed Property w/ Delaware Address Extrapolated Liability Sourced to Delaware Total Delaware Assessment ,000, ,000 12,500 12, ,000, ,000 5,500 Use 5, ,000, ,000 11,200 Actual 11, ,000,000 90,000 8,300 Data 8, ,000, ,000 4,500 4, ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , , ,000, , ,366 Documents Unavailable ,000, , ,182 Actuals 10, 725,000,000 1,420,000 42,000 2,968,905 3,010,905 Error Rate % Application of Penalties and Interest 3,763,631 Total Delaware Assessment 6,774,536 Documents Unavailable Page 15
16 Audit Process
17 Audit Process 3-7 years Multi-state Decreased decision making, increased company resources Third party contingency fee auditors In-depth review of books and records Potential estimation back to date of incorporation (DE 1991) Page 17
18 Top 3 rd Party Audit Firms # Firm Comments 1 Kelmar Associates LLC Leading audit firm for DE and certain other states 2 UPCH Owned by Xerox; maintain contracts with over 25 states 3 Audit Services US Maintain contracts with 46 states 4 Verus Financial LLC Leader in Life Insurance audits 5 Treasury Services Group LLC Bought Bankrupt APEX; newer firm Discovery Audit Services LLC Newer Firm outside LA; Performing audits for LA since Hertz & Herson Newer Firm, started in Innovative Advocates Group, Inc. Newer Firm, started in 2013 Page 18
19 Audit Concerns Retail and Service Industry Common Property Types/Concerns Property Type Gift Cards Concern Millions of gift cards go unredeemed every year and could be escheatable to the state of last known address or state of incorporation. Accounts Receivable Accounts Payable Service industries typically have a significant customer listing including both larger and smaller customers from different states Many suppliers from different states Payroll Multiple employees throughout many states hourly TPA Third Party Admin Self Insured Benefits Workers comp, etc. Rebates High number of customers; low redemption rates Page 19
20 Top 10 UCP Issues with Accounts Receivable
21 Top 10 UCP Issues with Accounts Receivable # Issue Risk 1 Complex Analysis Analysis of AR TB s and write off accounts Potential for errors throughout identification of population, remediation, etc. Could cause inflated populations, increased liability, etc. 2 Inclusion of Non AR transactions Sales Accounts (large data sets/populations) Increased efforts throughout remediation process Potential for increased liability and sample risk 3 Difficult to remediate Historic information is not accessible Harder to conceptualize Current customer not acceptable argument 4 Lack of AR prior filings Potential for increased UCP liability Non-compliance=greater audit risk 5 Transactions removed from Balance Sheet Multiple accounts Understand the business reason Inclusion of non write off related accounts Increased efforts throughout remediation process Page 21
22 Top 10 UCP Issues with Accounts Receivable # Issue Risk 6 Identification of population Netting of write off accounts Potential for inflated net credit population if related customers are not netted together Address information/no address information 7 Records available vs. researchable Potential for increased error rate and higher UCP exposure 8 Inconsistent treatment across entities Potential for mistreatment of population and remediation, possibly increasing UCP liability 9 De-Minimis accounts Automatic write off of small balances Potentially still owed as UCP 10 Burden of proof Typically burden is put on the customer to research if credit is owed. The audit process states that the burden or proof cannot be put on customer. Potentially results in customer saying a credit amount is owed, when it is not Page 22
23 Mitigation Strategies
24 Mitigation Strategies BDO offers a variety of services that can be utilized to help reduce exposure: Voluntary Disclosure Agreements (VDA) Agreement between the company and the state whereby the company comes forward with all unreported unclaimed property in exchange for the following: Reduced look back period Abatement of interest and penalties Removal of audit risk Control of workpapers Page 24
25 Mitigation Strategies BDO offers a variety of services that can be utilized to help reduce exposure: Feasibility Study Calculate the current exposure and potential for future exposure, as it relates to specified property type largely used for decision making. General Compliance Prospective filings for all property types; avoid interest and penalties, audit risk, etc. General Consulting Consulting on all unclaimed property related matters. Policies & Procedures Gift Card Management/Restructuring Page 25
26 UCP Industry Updates
27 UCP- Industry Updates DE VDA Program On February 19, DE sent approximately 200 letters to companies informing them to participate in its VDA program based on record of non-compliance or they may face being audited. These letters are in addition to letters sent in September that were followed by audit notices in December. Targeted companies: middle market companies with annual revenues of $100M and above. Potential audit concerns are alleviated when entering into DE VDA program Waives interest/penalties Waives right to audit VDA is 2 years vs. 3-7 year audit VDA void criteria is more favorable Page 27
28 UCP- Industry Updates DE VDA Program VDA Guidelines Comments Review of books/records Internal VS. Aggressive 3 rd party auditors Timeline 2 years 1-5 years less than audit Reachback years reduction of prior SOS VDA program, 5 year reduction of audit reachback Voids Included 90+ days 60 day difference of audit criteria Interest? No, waived Audit up to 25% interest Right to audit Waived With certain conditions Page 28
29 UCP- Industry Updates DE Audit Program On December 15, Delaware sent audit notices to companies that failed to participate in the VDA program after receiving a letter 2 months prior. VDA letters sent September 15. Unlike VDA s, UCP audits are performed by third party auditing firms that work for a contingency fee and may include interest, penalties, and increased look-back. Companies at highest risk incorporated in DE and/or significant operations in DE. Page 29
30 UCP- Industry Updates DE Audit Program Audit Guidelines Comments Review of books/records Timeline Aggressive third party contingency fee auditing firms 3-7 years Kelmar Associates, LLC, UPCH, Audit Services US, Verus Financial, LLC, Treasury Services Group LLC, Discovery, Hertz & Herson, Innovative Advocates Group, Inc. Reachback 1991 Voids included 30+ days Interest? 25% Uncertainty of application: automatic or case by case Page 30
31 UCP- Industry Updates PA Audit Notice The Pennsylvania Department of Treasury has been sending out self-audit review audit notices to many public and private companies within the state and outside the state seeking compliance with its unclaimed property laws. Failure to comply with notice requirements will likely result in full unclaimed property examination. Moreover, certain responses to the questionnaire may also elicit direct examination by the state. Targeted companies now include middle market companies that maintain annual revenues of $50M and above. Page 31
32 UCP Industry Updates - TX Domiciled Companies at High Risk for Unclaimed Property Audit by Texas Companies at RISK $75M and above in annual revenues Incorporated in TX or DE Domiciled in TX No or little filing history of escheat reports with TX and other states High incidence of M&A activity Received any notices from TX BART Division in last 6 months Under audit by another state Texas Voluntary Disclosure Agreements Accepted into program TX Audit Manual Brings companies into compliance Abatement of interest and penalties 6 month with possibility of extension Limited scope of review Page 32
33 UCP Industry Updates Texas Audit vs. VDA CATEGORY TX VDA Audit Penalty & Interest Audit Waiver Look-back Waived Audit waived unless misrepresentation or fraud 10 report years Up to max of 20% of assessment N/A 10 report years (statutorily Inc. date) Who Conducts Review Self review Third party audit firm Venue Texas Comptroller of Public Accounts Texas Comptroller of Public Accounts Timeline Less than 2 years ~ 3 to 6 years Page 33
34 UCP Litigation Temple-Inland, Inc. v. Cook Temple-Inland, Inc., a Delaware incorporated entity, was audited by Kelmar Associates on behalf of the State of Delaware beginning in 2008, and subsequently filed an administrative appeal regarding Kelmar s Report of Examination. Temple-Inland alleges that its substantive due process rights were violated due to the use of estimation. If Temple-Inland is successful, may have significant impact on Delaware s ability to estimate and/or the methods used to estimate a liability for years where records do not exist. Summary Judgments 3/17/16 State of Delaware ex rel. French v. Card Compliant LLC, et. al. Delaware Defendants are multiple retailers, incorporated in Delaware, that sell gift cards. Delaware Defendants did not keep any records of who purchased the gift cards. Without name and address information, the unredeemed gift card balances would be reportable to the Company s state of incorporation or formation. Card Compliant Defendants set up shell corporations incorporated in Ohio and Florida to hold the value of the unredeemed gift cards, because these states do not define unclaimed property to include unredeemed gift cards, and therefore this property was no longer reportable. Delaware claims that the various retailers outsourced their gift-card programs to a non-delaware third party in order to circumvent Delaware Escheats Law. If Delaware s claims succeed, this type of outsourcing arrangement will be subject to scrutiny/challenge. The decision could have ramifications for internal gift card arrangements. Page 34
35 UCP Litigation Plains All American Pipeline, L.P. v. Cook Delaware and Kelmar Associates notified Plains that it was the subject of an unclaimed property audit and sent initial requests for information. Plains objected to those requests on constitutional grounds, which Delaware rejected. Plaintiff alleges that Delaware s audit practices (1) constitute unreasonable searches and seizures under the 4th Amendment; (2) violate Plains due process rights under the 14th Amendment; (3) constitute the taking of private property for public use without just compensation; and (4) violate Plains right to equal protection. Plaintiff also challenges Delaware s right to estimate, similar to what Temple-Inland argues. In addition to challenging the estimation methodology employed by Delaware, the Plains complaint is worth watching insofar as it raises new challenges related to Delaware audit selection methods. Page 35
36 BDO Unclaimed Property Questionnaire
37 BDO Unclaimed Property Questionnaire Unclaimed Property Questionnaire 1)Does your company have revenues in excess of $50M Yes No 2)Has your company ever been subject to an unclaimed property audit or participated in a formal Voluntary Disclosure Program Yes No 3)Identify the state of incorporation/formation for the main entities with operations (bank accounts, general ledgers, accounts receivable, etc.) State of Inc. - Current State of Inc. - Prior 4)Does your company have a history of filing unclaimed property to any reporting jurisdiction Yes No Does your company have established policies and procedures related to unclaimed property (voided 5) checks, overpayments, escrow balances, unapplied cash, etc.) Yes No 6)Does your company have operations/locations in multiple states? Yes No completed questionnaire to Michael Kenehan at Mkenehan@bdo.com. Follow-up will be scheduled based on response date. Page 37
38 Questions?
39 Biographies
40 Biography Nick Boegel, JD, CPA, MBA. Nick Boegel comes to BDO with seventeen years of tax consulting experience. He has reviewed, researched and documented solutions for complex state and local tax issues in income and franchise, sales and use, payroll and employment, and property taxes and unclaimed property. He has expertise in identifying and serving multi-state client needs and performing creative tax and unclaimed property reviews to quantify potential savings via process improvements and prospective corporate restructuring projects. As the firm s Midwest Unclaimed Property Practice Leader, Nick has established professional relationships with many of the state unclaimed property administrators in handling client matters, successfully negotiated voluntary disclosure agreements on behalf of clients and provided audit representation services. In addition, Nick has significant escheat planning experience. nboegel@bdo.com Direct: Mobile: Prior to joining the firm, Nick worked with PriceWaterhouseCoopers, Arthur Andersen, Deloitte, and Reinhart Consulting providing state and local tax compliance, consulting and planning services for public and private companies. 330 E. Kilbourn Ave., Suite 750 Two Plaza East Milwaukee, WI Tel: Page 40
41 Biography Michael Kenehan, CPA, MBA. Michael has more than 11 years of combined experience in abandoned and unclaimed property (AUP) and internal audit related matters. He possesses vast experience in handling large unclaimed property audit engagements for the nation s largest contract AUP firm in a variety of industries including healthcare, retail, manufacturing, oil and gas, entertainment, food and beverage, automobile, and hospitality. Mike leverages his extensive knowledge of the audit process, property types, and the rules and regulations associated with AUP to assist clients in mitigating exposure and proactively addressing its escheat issues. Mkenehan@bdo.com Direct: Mobile: Market Street, 17 th Floor Philadelphia, Pa Michael is based out of the Philadelphia office and specializes in audit defense, escheat planning, general consulting, and voluntary disclosure agreements (VDA), etc. He has established professional relationships with many state unclaimed property administrators and offers clients with a unique perspective in dealing with all unclaimed property related matters. Prior to joining BDO, Michael worked with Kelmar Associates, LLC as a Senior Audit Manager in charge of unclaimed property audits contracted on behalf of various states. Michael also worked as a Team Leader in internal audit for ABC Supply Company. Tel: Page 41
42 BDO is the brand name for BDO USA, LLP, a U.S. professional services firm providing assurance, tax, financial advisory and consulting services to a wide range of publicly traded and privately held companies. For more than 100 years, BDO has provided quality service through the active involvement of experienced and committed professionals. The firm serves clients through 58 offices and more than 400 independent alliance firm locations nationwide. As an independent Member Firm of BDO International Limited, BDO serves multi-national clients through a global network of 1,328 offices in 152 countries. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. BDO is the brand name for the BDO network and for each of the BDO Member Firms. For more information please visit: Material discussed is meant to provide general information and should not be acted on without professional advice tailored to your firm s individual needs BDO USA, LLP. All rights reserved.
BDO KNOWLEDGE Tax Webinar Series California Update: Audit Invasion. Page 1
BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent
More informationNorth Carolina Association of CPAs State and Local Tax Conference Escheats Overview. December 10, 2014
North Carolina Association of CPAs State and Local Tax Conference Escheats Overview December 10, 2014 Notice The following information is not intended to be written advice concerning one or more Federal
More informationUnclaimed Property Compliance General Overview and Industry Update. The Unique Alternative to the Big Four
Unclaimed Property Compliance General Overview and Industry Update The Unique Alternative to the Big Four Agenda Unclaimed Property Overview Unclaimed Property Compliance Unclaimed Property Exemptions
More informationNortheast & Mid-Atlantic- Unclaimed Property Update & Pending Legislation
Northeast & Mid-Atlantic- Unclaimed Property Update & Pending Legislation September 27, 2016 BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK
More informationNew (but not necessarily good) Innovations and Best Practices. Fast Facts & Basic Background
New (but not necessarily good) Innovations and Best Practices Changes in Unclaimed Property requirements Fast Facts & Basic Background Origins in British Common Law Escheat Traditional Custodial *Definition:
More informationDelaware Opens Dramatic Voluntary Disclosure Program Aimed at Businesses Holding Unclaimed Property Payable to the State of Delaware
Delaware Opens Dramatic Voluntary Disclosure Program Aimed at Businesses Holding Unclaimed Property Payable to the State of Delaware FRENCH SLAUGHTER, PARTNER T: +1 202 857 1745 fslaughter@mcguirewoods.com
More informationUnclaimed Property: What You Need to Know ~ Part 1 ~ Heela Popal & Troy Wangen June 15, :00p 3:00p 25084
Unclaimed Property: What You Need to Know ~ Part 1 ~ Heela Popal & Troy Wangen June 15, 2016 2:00p 3:00p 25084 Legal Disclaimer This presentation does not constitute legal, financial, accounting or any
More informationIndustry Specific Breakout: Oil and Gas Audit Issues. UPPO Presentation Disclaimer
Industry Specific Breakout: Oil and Gas Audit Issues Adrian Sadler -BP Pam Wentz -Keane UPPO Presentation Disclaimer Use of the Unclaimed Property Professionals Organization, Inc., (UPPO) name or copyrighted
More informationTake Comfort in Compliance. Crowe Unclaimed Property Services
Take Comfort in Compliance Crowe Unclaimed Property Services Audit / Tax / Advisory / Risk / Performance Smart decisions. Lasting value. States are increasingly assertive about their rights to unclaimed
More informationUnclaimed Property: The Changing Landscape
Unclaimed Property: The Changing Landscape Mark. K. Webster / Treasury Alliance Group LLC Robert S. Peters / Duff & Phelps, LLC March 12th, 2010 Agenda Unclaimed Property: Overview The Perfect Storm: State
More informationUnclaimed Property Essentials
Unclaimed Property Essentials Presented by: Heela Popal, PricewaterhouseCoopers LLP Robert Joseph, True Partners Consulting LLC UPPO Presentation Disclaimer Use of the Unclaimed Property Professionals
More informationUnclaimed Property Program Holder Reporting Overview
Unclaimed Property Program Holder Reporting Overview Overview Introduction What is Unclaimed Property? Common Definitions History of Unclaimed Property Law Results of the Program Holder Obligations Reporting
More informationOhio Tax. Workshop K. Tuesday, January 24, :00 p.m. to 4:00 p.m. Tuesday & Wednesday, January 24 25, 2017 Hya Regency Columbus, Columbus, Ohio
26th Annual Tuesday & Wednesday, January 24 25, 2017 Hya Regency Columbus, Columbus, Ohio Ohio Tax Workshop K Unclaimed Property Key Developments Including the Temple Island Case, Navigating through an
More informationState of Florida Division of Unclaimed Property Self-Audit Manual
State of Florida Division of Unclaimed Property Self-Audit Manual DFS-UP-230 Effective date 04-27-09 Incorporated into Rule 69I-20.050, F.A.C. PROCEDURES FOR MASS MAILING OF COMPLIANCE LETTERS 1) Financial
More informationHow the Revised Uniform Unclaimed Property Act is Impacting A/P
May 7-9, 2017 How the Revised Uniform Unclaimed Property Act is Impacting A/P by Karen Anderson Senior Manager, KPMG LLP May 9, 2017 11:15 AM 12:15 PM Disclaimers The following information is not intended
More informationAchieving Unclaimed Property Compliance
Your State Association Presents Achieving Unclaimed Property Compliance Program Materials Use this document to follow along with the webinar presentation. Please test your system before the broadcast.
More informationManaging Unclaimed Property Risks in the Music Industry
Managing Unclaimed Property Risks in the Music Industry Crowe TM Unclaimed Property Solution Audit Tax Advisory Risk Performance The complex economics of the music industry are undergoing considerable
More informationAudit. 6 Most Important Ways to Avoid an Unclaimed Property Audit
6 Most Important Ways to Avoid an Unclaimed Property Audit The processing of unclaimed property seems like a behind-the-scenes function that should be managed quietly by finance directors and accounting
More informationFINANCIAL REPORTING. How to comply with the undisclosed liability and reporting requirements. Unclaimed Property
Home Online Publications Journal of Accountancy Online Issues February 2004 Unclaimed Property FINANCIAL REPORTING How to comply with the undisclosed liability and reporting requirements. Unclaimed Property
More informationGeneral Information This brief provides general information on unclaimed property and defines some commonly used terms.
Unclaimed Property Briefs General Information This brief provides general information on unclaimed property and defines some commonly used terms. What is Unclaimed Property? Unclaimed Property is money
More informationIntroduction to Unclaimed Property
Introduction to Unclaimed Property Sonia Walwyn Duff & Phelps Hermanna Daniels Rexel Holdings Deborah Beauchamp StoneRiver 1 UPPO Presentation Disclaimer Use of the Unclaimed Property Professionals Organization,
More informationShareholder Services Association Webinar: Back to the Basics: Introduction to Unclaimed Property
Shareholder Services Association Webinar: Back to the Basics: Introduction to Unclaimed Property Welcome: Abby Cowart, Executive Director, SSA Moderator: Mark Gereb Verizon Presenters: Anthony Vitellozzi
More informationUnclaimed Property 101 The Basics. What is Unclaimed Property. Common Terms 2011 UPPO ANNUAL CONFERENCE MARCH 6-9, 2011
Unclaimed Property 101 The Basics Valerie Jundt UPPO Past President 2010-2011 1 What is Unclaimed Property Definition: Intangible Personal Property that has gone unclaimed by the rightful owner (i.e. remained
More informationUNCLAIMED FINANCIAL ASSETS Presentation by: CPA, Gideon Nzioki Senior Auditor, Holders, Thursday, 21 st June Uphold public interest
UNCLAIMED FINANCIAL ASSETS Presentation by: CPA, Gideon Nzioki Senior Auditor, Holders, Thursday, 21 st June 2018 Uphold public interest Presentation Agenda Overview of Unclaimed Financial Assets (UFA)
More informationCreating an Effective Unclaimed Property Program
Creating an Effective Unclaimed Property Program Presented by: Ann (Moore) Fulmer, Keane Jeff Henshall, Ryan UPPO Presentation Disclaimer Use of the Unclaimed Property Professionals Organization, Inc.,
More information2nd Asset Management Seminar - Kisumu, Kenya; 28th 30th September, 2016
2nd Asset Management Seminar - Kisumu, Kenya; 28th 30th September, 2016. Jacob O. Owade Lead Unclaimed Financial Assets Practice Experienced Unclaimed Financial Assets Specialist Honours Graduate - City
More informationOverview of Unclaimed Property
Overview of Unclaimed Property Tax Section of the Texas State Bar Legal Overview Session Texas Comptroller s Office Austin, Texas October 5, 2015 William S. King Associate General Counsel Keane Charolette
More informationAgenda. Department of Revenue 1/22/2016. DOR & Revenue Overview. Ron Johnson Division Director Taxpayer Services & Processing
DOR & Revenue Overview Ron Johnson Division Director Taxpayer Services & Processing Steve Harbin Manager Unclaimed Property Section of Local Government Services Division Questions Agenda Department of
More informationWhat the Escheat? All You Need to Know About Unclaimed Property! October 5, 2017
What the Escheat? All You Need to Know About Unclaimed Property! October 5, 2017 Welcome! Disclaimer: This presentation and applicable material are intended for general education purposes and nothing in
More informationThe Unclaimed Financial Assets: Progress, Challenges and the role of Accounting professionals
The Unclaimed Financial Assets: Progress, Challenges and the role of Accounting professionals By: FCPA Kellen E. Kariuki, MBS Chief Executive Officer June 14, 2017 UFAA mandate & role The Unclaimed Financial
More informationHandling Unclaimed or 1. Abandoned Wages: What Payroll Needs to Know
Handling Unclaimed or 1 Abandoned Wages: What Payroll Needs to Know Presented Wednesday, February 25, 2015 2 RCH Credit 3 To earn RCH, you must Stay on the webinar for the full 60 minutes Be watching the
More informationUNCLAIMED FINANCIAL ASSETS Presentation by: Unclaimed Financial Assets Authority Monday, 27 th November Uphold public interest
UNCLAIMED FINANCIAL ASSETS Presentation by: Unclaimed Financial Assets Authority Monday, 27 th November 2017 Uphold public interest Presentation Agenda Overview of Unclaimed Financial Assets (UFA) Act
More informationAn Executive Guide to Unclaimed Property
An Executive Guide to Unclaimed Property What is Unclaimed Property? Unclaimed property is any form of intangible personal property that has gone unclaimed by the rightful owner after a specified period
More informationIntroduction to Unclaimed Property. UPPO Presentation Disclaimer. UPPO Antitrust UPPO has a policy of strict compliance with federal antitrust laws.
Introduction to Unclaimed Property Sonia Walwyn Duff & Phelps Hermanna Daniels Rexel Holdings Deborah Beauchamp StoneRiver UPPO Presentation Disclaimer Use of the Unclaimed Property Professionals Organization,
More informationAbbreviated Unclaimed Property Dormancy Periods
Abbreviated Unclaimed Property Dormancy Periods Stephen G. Harris and Phyllis J. Shambaugh States are seeking ways to get more money faster. As the authors explain, one method they are using is to speed
More informationYou Have Been Assigned Responsibility for Unclaimed Property Compliance Now What?
You Have Been Assigned Responsibility for Unclaimed Property Compliance Now What? With more and more states focused on unclaimed property compliance, knowledgeable businesses have taken steps to assign
More informationSample Policy and Procedure Manual
Unclaimed Property: A Reporting Process and Audit Survival Guide By Tracey L. Reid Copyright 2008 by John Wiley & Sons, Inc. appendix Sample Policy and Procedure Manual XYZ COMPANY Unclaimed Property Policies
More informationThe Essentials of Reporting & Compliance Part 2
The Essentials of Reporting & Compliance Part 2 Jennifer Brown, Manager, Holder Education and Research Unit, N.Y. State Comptroller s Office Kathy Janes, CPA, Director of Unclaimed Property, Oklahoma Treasury
More informationXYZ COMPANY UNCLAIMED PROPERTY POLICIES AND PROCEDURES MANUAL
APPENDIX C SAMPLE POLICY AND PROCEDURE MANUAL XYZ COMPANY UNCLAIMED PROPERTY POLICIES AND PROCEDURES MANUAL LAST UPDATED JULY 20XX UNCLAIMED PROPERTY POLICIES & PROCEDURES I. A PURPOSE: Entity is dedicated
More informationUnclaimed Property Issues in the Insurance Industry: Be Prepared for Changes
August 2017 Unclaimed Property Issues in the Insurance Industry: Be Prepared for Changes An article by Marc T. Grossman; Christopher J. Hopkins, CPA; and Michael R. Unger Audit / Tax / Advisory / Risk
More informationPresenting a live 110-minute teleconference with interactive Q&A. Today s faculty features:
Presenting a live 110-minute teleconference with interactive Q&A Unclaimed Property: Mitigating Risks Arising From Tougher State Enforcement Identifying Unclaimed Property, Sharpening Compliance, and Tracking
More informationSTATE OF FLORIDA DEPARTMENT OF FINANCIAL SERVICES DIVISION OF UNCLAIMED PROPERTY
STATE OF FLORIDA DEPARTMENT OF FINANCIAL SERVICES DIVISION OF UNCLAIMED PROPERTY GENERAL AUDIT PROCESS FOR THE IDENTIFICATION, AUTHORIZATION, GENERAL LEDGER AND/OR SECURITIES AUDITS, CONTRACTOR-ASSISTED
More informationPresented by: Heela Popal PricewaterhouseCoopers LLP Carla McGlynn Unclaimed Property Consulting & Reporting LLC All Rights Reserved
Presented by: Heela Popal PricewaterhouseCoopers LLP Carla McGlynn Unclaimed Property Consulting & Reporting LLC Use of the Unclaimed Property Professionals Organization, Inc., (UPPO) name or copyrighted
More informationNOTICE OF PROPOSED RULE. Proof of Ownership and Entitlement to Unclaimed Property
DEPARTMENT OF FINANCIAL SERVICES Division of Accounting and Auditing NOTICE OF PROPOSED RULE RULE NO.: 69I-20.0021 69I-20.0022 69I-20.030 69I-20.034 69I-20.038 69I-20.040 69I-20.041 RULE TITLE: Procedures
More informationAIRPORT NOISE AND CAPACITY ACT OF 1990
AIRPORT NOISE AND CAPACITY ACT OF 1990 P. 479 AIRPORT NOISE AND CAPACITY ACT OF 1990 SEC. 9301. SHORT TITLE This subtitle may be cited as the Airport Noise and /Capacity Act of 1990. [49 U.S.C. App. 2151
More informationComprehensive Unclaimed Property Compliance
Comprehensive Unclaimed Property Compliance Compliance Challenges Abandoned Property Alert Is your organization complying with state regulations on unclaimed property reporting? When you hold items such
More informationUnclaimed Property. What Is It & What To Do With It. Susan Vance Compliance Officer, FSITrack
Unclaimed Property What Is It & What To Do With It Susan Vance Compliance Officer, FSITrack What is Unclaimed Property? Intangible property needing to be reunited with its owner U/P Filing Applies To..
More informationEAST 34 th STREET HELIPORT. Report 2007-N-7
Thomas P. DiNapoli COMPTROLLER OFFICE OF THE NEW YORK STATE COMPTROLLER DIVISION OF STATE GOVERNMENT ACCOUNTABILITY Audit Objectives... 2 Audit Results - Summary... 2 Background... 3 Audit Findings and
More informationNEW JERSEY LAW REVISION COMMISSION. Final Report Relating to Unclaimed Property. December 20, 2018
NEW JERSEY LAW REVISION COMMISSION Final Report Relating to Unclaimed Property December 20, 2018 The work of the New Jersey Law Revision Commission is only a recommendation until enacted. Please consult
More informationUnclaime d Property. TeleStrategies Communications Taxation 2016 Wires or Wireless, Don t Get Tangled by Unclaimed Property.
Unclaime d Property TeleStrategies Communications Taxation 2016 Wires or Wireless, Don t Get Tangled by Unclaimed Property May 17, 2016 Disclaimer The following information is not intended to be written
More informationState Tax Return. Ohio Supreme Court Breaks from the Pack and Finds that Ohio Must Pay Claimants Interest on Unclaimed Funds
September 2009 State Tax Return Volume 16 Number 3 Ohio Supreme Court Breaks from the Pack and Finds that Ohio Must Pay Claimants Interest on Unclaimed Funds Phyllis J. Shambaugh Columbus 614.281.3824
More informationCathay Pacific Airways Limited Abridged Financial Statements
To provide shareholders with information on the results and financial position of the Group s significant listed associated company, Cathay Pacific Airways Limited, the following is a summary of its audited
More informationINSURANCE INDUSTRY DEVELOPMENTS
Summer 2011: Volume 9, Issue 3 The first unclaimed property compliance quarterly newsletter, published exclusively by Keane since 2003. Keane is the country s leading provider of unclaimed property communication,
More informationRequest for Proposals
E CONOMIC DEVELOPMENT AUTHORITY of the City of Norfolk Board of Directors Officers Robert E. Garris, Jr., Chairman Executive Director Michael W. Lee, Vice Chairman Peter Chapman Jeffrey F. Brooke Kim Brown
More informationPLC. IFRS Summary Financial Statement (excluding Directors Report and Directors Remuneration Report) Year ended November 30, 2006
C A R N I V A L PLC IFRS Summary Financial Statement (excluding Directors Report and Directors Remuneration Report) Year ended November 30, 2006 Registered number: 4039524 The standalone Carnival plc consolidated
More informationCriteria for an application for and grant of, or variation to, an ATOL: Financial
Consumer Protection Group Air Travel Organisers Licensing Criteria for an application for and grant of, or variation to, an ATOL: Financial ATOL Policy and Regulations 2016/01 Contents Contents... 1 1.
More informationAn Unclaimed Intangible Property Program for Ontario
for Ontario Introduction A wide variety of intangible property currently lies unclaimed in various institutions in Ontario. The 2012 Ontario Budget announced the government s intention to establish a program
More informationPage 1 of 7 Weekly State Tax Report: News Archive 2012 0 Perspective 2012 TM-WSTR 3 Unclaimed Property Unclaimed property accounts or items held by one party belonging to another who has not exercised
More informationCase 1:16-cv JL Document 10 Filed 10/21/16 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE
Case 1:16-cv-00290-JL Document 10 Filed 10/21/16 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE ZAP D GAMES, L.L.C., a ) New York Limited Liability Company; ) ZEV SHLASINGER,
More informationOHIO DIVISION OF UNCLAIMED FUNDS
WEBSITE ADDRESS: WWW.COM.STATE.OH.US/UNFD OHIO DIVISION OF UNCLAIMED FUNDS 2005 Annual Report of Unclaimed Funds Forms, Instructions & Information Table of Contents Electronic Reporting Options... 1 News
More informationR E P O R T A N D R E M I T T A N C E D U E N O V E M B E R 1
INSTRUCTIONS FOR BUSINESS REPORTING AND REMITTING OF UNCLAIMED PROPERTY R E P O R T A N D R E M I T T A N C E D U E N O V E M B E R 1 Y O U N G B O O Z E R, T R E A S U R E R A L A B A M A U N C L A I
More informationAverage annual compensation received by full-time spa employees.
1 Introduction This report presents the findings from the employee compensation and benefits section of the 2017 U.S. Spa Industry Study. The study was commissioned by the International SPA Association
More informationUnclaimed Property Audit or VDA Program: The Delaware Dilemma
Unclaimed Property Audit or VDA Program: The Delaware Dilemma November 28, 2017 Presented by: Mary Jane Wilson-Bilik Phillip Stano Wilson Barmeyer Liz Cha and State of Delaware, SOS VDA Administrator Alison
More informationBritish Columbia. property society. Annual report unclaimedpropertybc.ca
British Columbia Unclaimed property society Annual report 2014 unclaimedpropertybc.ca Reuniting Forgotten Dollars with their Rightful Owners Message from the Chair and Executive Director At the BC Unclaimed
More informationCathay Pacific Airways Limited Abridged Financial Statements
To provide shareholders with information on the results and financial position of the Group s significant listed associated company, Cathay Pacific Airways Limited, the following is a summary of its audited
More informationProperty And Money. Property And Money
We have made it easy for you to find a PDF Ebooks without any digging. And by having access to our ebooks online or by storing it on your computer, you have convenient answers with property and money.
More informationIssued by the Department of Transportation on the 26 th day of May, 2015
Order 2015-5-19 Served May 26, 2015 DEPARTMENT UNITED OF STATES TRANSPORTATION OF AMERICA UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C. Issued by the Department
More informationAUDITING UNCLAIMED FINANCIAL ASSETS 1. BANKING SECTOR Presentation by: CPA John Mwangi November Uphold public interest
AUDITING UNCLAIMED FINANCIAL ASSETS 1. BANKING SECTOR Presentation by: CPA John Mwangi November 2017 Uphold public interest FRAMEWORKS Legal Reporting Auditing Unclaimed Assets Companies Act 2015- Incorporation
More informationUnclaimed Property Reporting 101: The Principles of Escheatment & Guide to Compliance
Unclaimed Property Reporting 101: The Principles of Escheatment & Guide to Compliance Introduction When you were tasked with managing your organizations unclaimed property program, how many of you asked
More informationDOWNLOAD OR READ : UNCLAIMED PROPERTY A REPORTING PROCESS AND AUDIT SURVIVAL GUIDE PDF EBOOK EPUB MOBI
DOWNLOAD OR READ : UNCLAIMED PROPERTY A REPORTING PROCESS AND AUDIT SURVIVAL GUIDE PDF EBOOK EPUB MOBI Page 1 Page 2 unclaimed property a reporting process and audit survival guide unclaimed property a
More informationUnited States USCIS Final Rule Contains Significant Changes for AC21 Provisions
United States USCIS Final Rule Contains Significant Changes for AC21 Provisions At the end of 2016, the United States Citizenship and Immigration Services ( USCIS ) issued a final rule 1 that affects several
More informationAmerisearch Background Alliance Privacy Policy
Amerisearch Background Alliance Privacy Policy Amerisearch Background Alliance hereafter known as Amerisearch respects individual privacy and values the confidence of its customers, employees, consumers,
More informationUnclaimed property: Considerations for corporate treasury and finance personnel Received (in revised form): 30 March, 2009
Unclaimed property: Considerations for corporate treasury and finance personnel Received (in revised form): 30 March, 2009 Josiah S. Osibodu is a director in the National Unclaimed Property Group, based
More informationOPERATING AND FINANCIAL HIGHLIGHTS
Copa Holdings Reports Financial Results for the Fourth Quarter of 2015 Excluding special items, adjusted net income came in at $31.7 million, or EPS of $0.73 per share Panama City, Panama --- February
More informationCoastside County Water District Board of Directors. Mary Rogren, Assistant General Manager
STAFF REPORT To: From: Coastside County Water District Board of Directors Mary Rogren, Assistant General Manager Agenda: August 14, 2018 Report Date: August 10, 2018 Subject: Resolution Adopting an Escheatment
More informationDebit Memo Reasons Airlines Reporting Corporation. All rights reserved. Updated March 14,
Debit Memo Reasons Categories Booking... 2 Chargeback... 3 Commission... 4 Exchange... 6 Fare... 15 Fee... 20 Miscellaneous... 21 Refund... 22 Tax... 23 FAQ s... 24 2017 Airlines Reporting Corporation.
More informationAAAE Rates and Charges Workshop Air Service Incentive Programs. Thomas R. Devine KAPLAN KIRSCH & ROCKWELL LLP October 2, 2012
AAAE Rates and Charges Workshop Air Service Incentive Programs Thomas R. Devine KAPLAN KIRSCH & ROCKWELL LLP October 2, 2012 Overview Airports are under increasing pressure to preserve and enhance air
More informationTexas Unclaimed Property
Texas Unclaimed Property Bryant Clayton -Holder Reporting Texas Comptroller of Public Accounts (CPA) Agenda General overview of Unclaimed Property (UP) Texas UP Statistics and Goals Overview of Texas UP
More informationOwnership Options for the HondaJet Explained
Ownership Options for the HondaJet Explained There are many ways to utilize and/or own a private aircraft ranging from leasing, chartering, full ownership, co-ownership, LLC partnership, joint ownership,
More informationOPERATING AND FINANCIAL HIGHLIGHTS. Subsequent Events
Copa Holdings Reports Net Income of US$113.1 Million and EPS of US$2.57 for the First Quarter of 2015 Excluding special items, adjusted net income came in at US$106.0 million, or EPS of US$2.41 per share
More informationANGLIAN WATER GREEN BOND
ANGLIAN WATER GREEN BOND DNV GL ELIGIBILITY ASSESSMENT Scope and Objectives Anglian Water Services Financing Plc is the financing subsidiary of Anglian Water Services Limited. References in this eligibility
More informationIssued by the Department of Transportation on the 12 th day of February, 2016 FINAL ORDER ISSUING INTERSTATE CERTIFICATE
Order 2016-2-10 Served: February 12, 2016 DEPARTMENT UNITED OF STATES TRANSPORTATION OF AMERICA UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C. Issued by
More informationCopa Holdings Reports Net Income of $49.9 million and EPS of $1.18 for the Second Quarter of 2018
Copa Holdings Reports Net Income of $49.9 million and EPS of $1.18 for the Second Quarter of 2018 Panama City, Panama --- Aug 8, 2018. Copa Holdings, S.A. (NYSE: CPA), today announced financial results
More informationSummit County Fiscal Office Auditor Division; Accounting Department Preliminary Audit Report. PREPARED FOR: John A. Donofrio Audit Committee
09-Accounting.Fiscal-64 PREPARED FOR: John A. Donofrio Audit Committee Approved by Audit Committee December 11, 2009 Summit County Internal Audit Department 175 South Main Street Akron, Ohio 44308 Bernard
More informationMETROPOLITAN WASHINGTON AIRPORTS AUTHORITY RONALD REAGAN WASHINGTON NATIONAL AIRPORT TRANSPORTATION NETWORK COMPANY SERVICES PERMIT NO.
METROPOLITAN WASHINGTON AIRPORTS AUTHORITY RONALD REAGAN WASHINGTON NATIONAL AIRPORT TRANSPORTATION NETWORK COMPANY SERVICES This Permit is granted to Lyft, Inc. ( Permit Holder ) pursuant to the provisions
More informationOPERATING AND FINANCIAL HIGHLIGHTS SUBSEQUENT EVENTS
Copa Holdings Reports Financial Results for the Third Quarter of 2016 Excluding special items, adjusted net income came in at $55.3 million, or adjusted EPS of $1.30 per share Panama City, Panama --- November
More informationSpirit Airlines Reports Fourth Quarter and Full Year 2016 Results
Spirit Airlines Reports Fourth Quarter and Full Year 2016 Results MIRAMAR, FL. (February 7, 2017) - Spirit Airlines, Inc. (NASDAQ: SAVE) today reported fourth quarter and full year 2016 financial results.
More informationHighlights from the Annual Results December 2007
Highlights from the Annual Results December 2007 Disclaimer The information in this document is taken from the BAA 2007 Annual Results ( the Results ) which were published on 11 March 2008 and other public
More informationCopa Holdings Reports Net Income of $57.7 million and EPS of $1.36 for the Third Quarter of 2018
Copa Holdings Reports Net Income of $57.7 million and EPS of $1.36 for the Third Quarter of 2018 November 14, 2018 PANAMA CITY, Nov. 14, 2018 /PRNewswire/ -- Copa Holdings, S.A. (NYSE: CPA), today announced
More informationCity and County of San Francisco
City and County of San Francisco Office of the Controller City Services Auditor RECREATION AND PARK DEPARTMENT: Concession Audit of Stow Lake Corporation March 3, 2009 CONTROLLER S OFFICE CITY SERVICES
More informationOPERATING AND FINANCIAL HIGHLIGHTS SUBSEQUENT EVENTS
Copa Holdings Reports Net Income of US$6.2 Million and EPS of US$0.14 for the Third Quarter of 2015 Excluding special items, adjusted net income came in at $37.4 million, or EPS of $0.85 per share Panama
More informationMy co-presenter is Jared Gustafson. Jared, did you want to go ahead and introduce yourself and give a little background?
Thank you to everyone who's able to join us this afternoon. Our first slide here is going to be a Disclaimer. While we get that up, I just want to say, "Thank you," and we're hoping to send you all off
More informationQ3 FY18 Business Highlights
Q3 FY18 RESULTS Q3 FY18 Business Highlights 1 2 3 4 5 6 7 Record passengers 7.1m, record revenues 423m Investing in growth 24% passenger growth in Q3 Disciplined cost management flat ex-fuel CASK Largest
More informationOfficial Journal of the European Union L 7/3
12.1.2010 Official Journal of the European Union L 7/3 COMMISSION REGULATION (EU) No 18/2010 of 8 January 2010 amending Regulation (EC) No 300/2008 of the European Parliament and of the Council as far
More informationDELAWARE ALL EYES ON. Senate Bill 13 Transforms Delaware Unclaimed Property Law IN THIS ISSUE: Spring 2017: Volume 15, Issue 1
Spring 2017: Volume 15, Issue 1 The first unclaimed property compliance newsletter, published exclusively by Keane since 2003. Keane is the country s leading provider of unclaimed property compliance solutions.
More informationM7 AEROSPACE LP
Page 1 2011-02-04 M7 AEROSPACE LP (TYPE CERTIFICATE PREVIOUSLY HELD BY FAIRCHILD AIRCRAFT INCORPORATED) Amendment 39-16577 Docket No. FAA-2011-0014 Directorate Identifier 2010-CE-066-AD PREAMBLE Effective
More informationEstablishes a fare structure for Tacoma Link light rail, to be implemented in September 2014.
RESOLUTION NO. R2013-24 Establish a Fare Structure and Fare Level for Tacoma Link MEETING: DATE: TYPE OF ACTION: STAFF CONTACT: PHONE: Board 09/26/2013 Final Action Ric Ilgenfritz, Executive Director,
More informationUNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C.
Order 2016-1-3 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, D.C. Issued by the Department of Transportation on the 7 th day of January, 2016 United Airlines,
More informationThe Essentials of Reporting & Compliance Part 1
The Essentials of Reporting & Compliance Part 1 Phillip Carlton, Assistant Chief of Unclaimed Property, Florida Department of Financial Services Jennifer Brown, Manager, Holder Education and Research Unit,
More informationUNCLAIMED PROPERTY Reporting & Updates
UNCLAIMED PROPERTY Reporting & Updates ILLINOIS STATE TREASURER S OFFICE WWW.ILLINOISTREASURER.GOV/ICASH Welcome! IL County Treasurer s Association Spring Conference April 10, 2018 Springfield, IL Contact
More information