@BDO USA Tax · 18/03/2015 · BDO KNOWLEDGE Webinar Series ‒ Is Texas Becoming the New Delaware for Unclaimed Property Audits? (Part II) Page 1 BDO USA, LLP, a Delaware limited

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BDO KNOWLEDGE Webinar Series ‒ Is Texas Becoming the New Delaware for Unclaimed Property Audits? (Part II)

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 member firms. @BDO_USA_Tax

Is Texas Becoming the New Delaware for Unclaimed Property Audits? (Part II) National Unclaimed Property Practice, BDO USA, LLP Presenters: • Joe Carr, Partner & National Unclaimed Property Practice Leader • Ricardo Garcia, Senior Director & West Coast Unclaimed Property Practice Leader • Augusto Conde, Manager Unclaimed Property Services March 18, 2015

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CPE and Support

CPE participation requirements ‒ to receive CPE credit for this webcast: • You’ll need to actively participate throughout the program. • Be responsive to at least 75% of the participation pop-ups.

Certificate of attendance: If you are logged in the entire time and respond to all participation pop-ups, you will be able to print your certificate from the “Participation” section at the end of the webcast. If you log out before printing your certificate: • BDO USA professionals ‒ CPE will automatically be issued in CPE Tracking & Reporting at the end of every week.

A copy of your certificate will be sent after you have been issued credit. • All others will be emailed instructions on how to access your certificate.

Group participation ‒ to receive credit: • Sign-in sheets must list a Proctor name and CPA license number. • BDO USA professionals ‒ submit your sign-in sheets using a Training & Development Request in BDO Service

Now found at: BDOWorld > Applications & Resources > BDO Service Now > Click “Service Catalog” in the left menu, then under Training & Development, “Make a Request”.

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CPE and Support (continued)

Group participation ‒ to receive credit (continued): • Clients and Contacts ‒ email sign-in sheets to [email protected] within 24 hours of the webcast. • Alliance Members ‒ should proctor their own group participants. This process is detailed in the LearnLive

Participant Guide, which can be found by searching “LearnLive Participant Guide” on the Alliance Portal. Call LearnLive Support below for questions.

• Unfortunately, we cannot currently support group CPE for International Firms. Those wanting CPE must register and log in on their own computer.

Q&A: Submit all questions using the Q&A feature on the lower right corner of the screen. The presenter(s) will review and answer all questions submitted.

Technical Support: If you should have technical issues, please contact LearnLive: • Click on the Live Chat icon under the Support tab, OR • Call: 1-888-228-4088

mailto:[email protected]

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With You Today

Joseph Carr, J.D. Partner & National Unclaimed Property Practice Leader BDO USA, LLP 330 N. Wabash, 32nd Floor Chicago, IL 60611 (312) 616-3946 [email protected]

Augusto Conde III, CPA Manager, Unclaimed Property Practice BDO USA, LLP 3200 Bristol St., 4th Floor Costa Mesa, CA 92626 (714) 338-2547 [email protected]

Ricardo Garcia Senior Director & West Coast Unclaimed Property Practice BDO USA, LLP 3200 Bristol St., 4th Floor Costa Mesa, CA 92626 (714) 668-7308 [email protected]




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Agenda

1. Delaware Incorporated Entities Located in Texas – Unclaimed Property Update

2. Unclaimed Property Overview

3. Urgent – TX Domiciled Companies at High Risk for UP Audit by Texas

4. Testing Methodologies and Extrapolation Calculations

5. Self-Assessment Review Process

6. Ongoing Compliance Process

7. Questions

Delaware-Incorporated Entities Located in Texas – Unclaimed Property Update

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Delaware-Incorporated Entities Located in Texas – Unclaimed Property Update

Your company’s organizational structure may contain entities that are incorporated in states other than Texas (e.g., DE)

Delaware is a leader in state unclaimed property audits

SOS DE VDA program application dates have expired as of 9/30/14

Potential new VDA program to be formed

Current SOS DE VDA program has been very amenable to holder positions and concerns; predictable with implementing guidelines, etc.

Continued DE Audits – including piggyback audits of other states (e.g., TX)

When conducting your risk assessment consider the state of incorporation/formation in analysis

Note – Temple Inland case update – Delaware motion to dismiss case was denied; appears case will continue through legal system but may take years to resolve

Unclaimed Property Overview

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Unclaimed Property Types

All 50 states and the District of Columbia have enacted unclaimed property laws.

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

Suspense accounts

Unused/outstanding benefits (non-ERISA)

Credits written off to miscellaneous income/bad debt expense accounts

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Unclaimed Property Types (continued)

All 50 states and the District of Columbia have enacted unclaimed property laws.

Examples of unclaimed property, specific to the oil and gas industry:

Royalties held in suspense due to title disputes, pending litigation, etc.

Demurrage Claims due to delay in laytime

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Priority Rules

The U.S. Supreme Court in Texas v. New Jersey, established the following unclaimed property jurisdictional priority rules:

First, to the state of the owner’s last known address, if known, or

Second, to the state of the holder’s corporate domicile (i.e., state of incorporation for incorporated entities and state of formation/principal place of business for unincorporated entities).

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Unclaimed Property Introduction: Various States’ Dormancy Periods

“Dormancy Period”: A state prescribed period that begins from the date of creation of the property type (e.g., issuance date for checks) and ends on a certain legislatively defined date (e.g., typically 1-5 years) which measurers a period of time for which that property incurs no activity. Some examples include the following:

State Wages

A/R Credit

Balances

Third Party

Dividends Stocks A/P

Checks All other property B2B

(years

) (years) (years) (years) (years) (years)

DE 5 5 5 3 5 5 No

TX 1 3 3 3 3 3

No – Deferral Available

Urgent – TX Domiciled Companies at High Risk for UP Audit by Texas

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Urgent – TX Domiciled Companies at High Risk for Unclaimed Property Audit by Texas Risk Overview

Various 3rd Party Audit firms hired by TX to perform UP audits RFP went out in 2013, Performance begins 9/1/2013 Audits have already started 3rd party audit firms paid 10%-12% commission on findings LA, AR, OK and KY are also hot spots for audits (see attached audit list) No general SOL period Look-back period is 13 years or to date of incorporation (discretionary to state) Interest – variable rates Penalties – 10%

Impact to Clients Extrapolation giving rise to Million dollar assessments Significant P&L hit as clients are not “reserved” for exposure Piggyback other states = multistate audit Piggyback DE onto the audits, now 2 very difficult states TX and DE Aggressive pursuit of “voided checks” and “a/r credits”

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Urgent – TX Domiciled Companies at High Risk for Unclaimed Property Audit by Texas (continued)

RFP 206e Unclaimed Property Audit Services - Open Date: 06/21/13 02:00 PM Agency Requisition Number: 206E

Pursuant to Chapters 403 and 2254, Subchapter A of the Texas Government Code; and Chapters 72-75 of the Texas Property Code, the Comptroller of Public Accounts ( € Comptroller € ) announces the issuance of its Request for Proposals ( € RFP #206e € ) from qualified, independent unclaimed property audit firms to assist Comptroller in performing unclaimed property audit and related services for Comptroller, including but not limited to, the identification, processing, and collection of unclaimed property due to the State of Texas under Chapters 72-75 of the Texas Property Code. Comptroller reserves the right to award one or more contracts under this RFP. The successful respondent(s) will be expected to begin performance of the contract(s), if any, awarded under this RFP on or about September 1, 2013, or as soon thereafter as practical. The anticipated schedule of events is as follows: Issuance of RFP € May 10, 2013, 10:00 a.m. CT; Questions Due € May 24, 2013, 2 p.m. CT; Official Questions and Responses posted € June 7, 2013, or as soon thereafter as practical; Proposals Due € June 21, 2013, 2:00 p.m. CT; Contract Execution € August 1, 2013, or as soon thereafter as practical; and Commencement of Project Activities € September 1, 2013, or as soon thereafter as practical. The Comptroller reserves the right, in its sole discretion, to modify this schedule of events…

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Who are These Third-Party Auditing 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 (TSG) Bought Bankrupt APEX; newer firm 2012-2013

6 Discovery Audit Services LLC Newer Firm outside LA; Performing audits for LA since 2003

7 Hertz & Hertz Newer Firm, started in 2012-2013

8 Innovative Advocates Group, Inc. Newer Firm, started in 2013

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Urgent – TX Domiciled Companies at High Risk for Unclaimed Property Audit by Texas (continued) Below are some factors that put both private and public companies at risk for an unclaimed property audit:

$200M and above in annual revenue Incorporated in TX or DE Domiciled in TX No or little filing history of escheat reports with TX and other states Filing only negative reports Filing an initial report that only contains recent transactions (current due property) Recent mergers, acquisitions, reorganizations and reincorporation Received any notices from BART division in last 6 months regarding unclaimed property Under audit by another state Company or industry in the news Claiming unclaimed funds without having history of reporting Others in industry currently under audit Random selection

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State of Texas – Audit Specifics – Per State Audit Manual

Audit Look-Back Period

Texas generally limits the audit period to the last ten reports years

• An exception occurs when the holder has previously been audited in the past ten years and any current audit would not reach back to years covered in the prior audit.

An audit of equity related property (stocks, dividends, dividend reinvestment programs, demutualization, royalties, etc.) conducted by one of our contract auditors is not considered a “prior audit” and has no effect on our nominal ten (report) year audit period.

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State of Texas – Audit Specifics - Per State Audit Manual (continued)

Pre-audit Research

Determine company’s state and date of incorporation/formation and any changes to the state of incorporation/formation

Determine if the company has a history of filing unclaimed property reports.

• What years and property types were reported?

• Does the company have copies of all prior reports and details?

Determine if the company has unclaimed policies and procedures

Determine if the company is applying the Priority Rules of Escheat properly

Review the company’s trial balance or chart of accounts to determine accounts that may hold potential unclaimed property.

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State of Texas – Audit Specifics - Per State Audit Manual (continued)

Testing Procedures

Review listing of all open and closed bank accounts

• A review of closed bank accounts will be conducted to determine how outstanding checks were addressed at time of closing

Review of liability accounts and income accounts to determine if checks or customer credits have been written off

Review procedure for contacting payees of uncashed checks or open customer credits

Review the contra or related expense accounts to determine if outstanding checks or customer credits are reversed to the expense account

Review listing of void checks to determine if debt to payee was resolved

• Although some states offer a void waiver (e.g., 90 days), the state of Texas does not.

Testing Methodologies and Extrapolation Calculations

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Texas: Extrapolation Techniques

Texas does not appear to address estimation and extrapolation methodologies for unclaimed property reporting in statute, regulatory or administrative guidance. Texas generally follows unclaimed property estimation and extrapolation techniques followed by other states (e.g. Delaware), when extrapolation is deemed warranted.

The determination of whether or not to extrapolate may depend on factors such as:

• Historical unclaimed property reporting practices

• Filing history

• Property types and amounts previously reported

• Materiality of errors found for periods where records were reviewed

• Record availability and reliability

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Exposure Quantification Accounts Payable Extrapolation

Accounts Payable O/S Checks – 12/31/2007 ___________________________________ = % x Federal 1120 Gross Receipts Federal 1120 Gross Receipts – 12/31/2007 (Prior Years)

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Example of Extrapolation

Transaction Year Report Year Sales

Total Unremediated Unclaimed Property

Due All States

Total Unremediated Unclaimed Property

w/ Texas Address Plus Extrapolation

Total Liability Self Review Texas Only

Total Liability Audit Texas Only

Difference between Self-Review & Audit

Error Rate (Total Unremediated All States/Sales) 0.02%

2012 2015 $900,000,000 $150,000 $100,000 $100,000 $100,000 $0

2011 2014 $850,000,000 $175,000 $125,000 $125,000 $125,000 $0

2010 2013 $800,000,000 $140,000 $110,000 $110,000 $110,000 $0

2009 2012 $750,000,000 $130,000 $100,000 $100,000 $100,000 $0

2008 2011 $700,000,000 $95,000 $75,000 $75,000 $75,000 $0

2007 2010 $680,000,000

Doc

umen

ts U

nava

ilabl

e

EXTR

APO

LATE

D

AMO

UN

T

$117,300 $117,300 $117,300 $0

2006 2009 $675,000,000 $116,438 $116,438 $116,438 $0

2005 2008 $665,000,000 $114,713 $114,713 $114,713 $0

2004 2007 $550,000,000 $94,875 $94,875 $94,875 $0

2003 2006 $625,000,000 $107,813 $107,813 $107,813 $0

Actuals $4,000,000,000 $690,000 $1,061,138 $1,061,138 $1,061,138 $0

Application of Penalties and Interest $0 $476,243 $476,243

Total $1,061,138 $1,537,380 $476,243

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Common Issues with Extrapolation Techniques

How to Determine What Goes in Your Numerator What is gross vs. net for the extrapolation calculation? The more logical vs. reality used in an audit Very difficult for holders to understand and accept which can lead to setting false expectations

internally about potential risk exposure at CFO level

Base Periods – Important Considerations What records are available? Are these years complete and researchable? What does “researchable” mean? What if I could recreate data to fill in holes? What if I have a check register that shows all checks written with addresses going back to 1995

and no DE addresses, am I done?

Voids Treatment – How do I deal with this? Is a master void list available? Texas does not allow a void waiver Remediation of Voids – Remember strict liability?

Self-Assessment Review Process

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How to Get Started

Risk Assessment Evaluate company’s risk profile by identifying relevant risk factors

• $200M and above in annual revenue • Incorporated in TX or DE • Domiciled in TX • No or little filing history of escheat reports with TX and other states, etc. • M&A Activity/System Conversions

Determine property types relevant to your industry Determine record researchability and availability in the context of an unclaimed property review.

• What is meant by researchable and available records? • Impact of system conversion on record availability • Personnel turnover

Current and historical unclaimed property compliance posture • Determine whether prior unclaimed property VDAs and audits have occurred • Prior compliance reporting history

o Property types previously reported o Years and states reported

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How to Get Started (continued)

Risk Assessment - Common Questions Posed by Decision Makers

Cost of conducting a self-assessment review vs. cost of non-compliance

Availability of resources to undertake this project

Subject matter expertise

Timing to complete self-assessment

Likelihood of being identified for audit in the near future

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TX Voluntary Disclosure Process Step 1 File VDA

File VDA Kick-off Meeting with State

Step 2 Scoping

Preliminary Document Request -Tax Returns -Trial Balance - Prior UP Reports

Phase I Templates -Bank Acct Listing - AP Questionnaire -AR Questionnaire - Data System Log -AR Listing - DE Matrix -TPA Listing

Define -Property Types -Base Years -Entities

Step 3 Data Dig

Data Gathering -Manual Records (including offsite storage) -Electronic Records

Examples -O/S Checklist - Bank Reconciliations -Bank Statements - AR Aging Reports -Void Reports - GL Detail

Step 4 Data Analysis & Remediation

Phase II Templates -AR Netting Analysis - TPA Scheduling Template -AR Scheduling Template - GL Disposition Scheduling Template -AP Scheduling Template - Equity Scheduling Template

Sampling/ Full Testing Remediation

Step 5 Exposure Quantification

Models Exposure Calculation Adjustments

-Exemptions - Legal Positions (e.g., bankruptcy) -Distorted Transactions - Remediation Positions

Finalize Proposed Settlement Ranges

Step 6 Settlement

Presentation of Proposed Liability to State

Settlement of Liability & Execution of Closing

Agreement Final Payment & Reporting

Submission

Step 7 Best Practices

Policies & Procedures Ongoing Compliance Other State VDAs

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Texas Voluntary Disclosure Process (continued)

Overview

File request to join VDA with Business Activity Research Team (“BART”)

Request can be filed on an anonymous basis

No ongoing audits or prior VDAs

Complete state of Texas nexus questionnaire

Execute VDA with state of Texas

Six months to complete review and file VDA

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Texas Voluntary Disclosure Process (continued)

Texas Nexus Questionnaire

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Texas Voluntary Disclosure Process (continued) Texas Voluntary Disclosure Agreement

Ongoing Compliance Process

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Compliance Process Overview

Compilation of reportable transactions

Identification of exemptions/deductions

Due diligence notification letters

Reconciliation of general ledger unclaimed property liability account

Reporting and remitting funds to the various jurisdictions

Policies and Procedures

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Timeline Summer 2015 Compliance

Reports and remittance to states

Dec 15 Jan 31

Feb 1 – Feb 30

Mar 1 – Mar 31

April 30

May 1 – May 15

May 16 – Jun 7

July 1st

Data Gathered

Validate data

Due diligence

Compile DDL

responses

Reissue checks

Prepare reconciliation

Prepare UP reports & check

request

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Identification of Deferral

The business to business deferral offered by the state of Texas is NOT AN EXEMPTION.

Statutory Determination

• Does the deferral apply to the property type in question?

Application

• What constitutes an on-going relationship?

o Payment received

o Invoice issued

o Amounts refunded

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Due Diligence Notification Letters

Prior to reporting unclaimed property to the state, most jurisdictions require companies to reach out to owners of the property via a due diligence letter as a last-ditch effort to reunite the owner with their property.

Although due diligence requirements vary from jurisdiction to jurisdiction, the following is specific to Texas due diligence requirements:

• Due diligence must be sent for amounts more than $250

• Timing of mailing due diligence letters – Company must mail a written notice to the owner no later than May 1 before remitting property the following July.

• If mail is returned to you, a second notice is not required.

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Due Diligence Notification Letters Overview of Due Diligence Notification Process

a) Letters Prepared & Mailed

b) Responses Tracked Via

BDO Unclaimed Property Compliance - Due Diligence Responses

Property Type

Check # or Acct # (if

applicable)FEIN/ SSN

Business Name

Business Indicator

("X")Last

NameFirst

Name MI Address City State Zip

Last Trans Date Amount

Bank Account Number

GL Account Number

Legal Entity Name

Entity Number

Action Required

For Multiple Entity Filing

c) Track responses and necessary actions steps

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Reporting and Remitting Funds

Effective with the 2014 reporting cycle, companies are now required to file reports online.

• Filings must be in state required NAUPA II format

• State offers tools to assist holders in preparing filings

Texas law requires taxpayers and other entities that paid $100,000 or more in the previous state fiscal year in any one type of tax, fee or unclaimed property to make their payments using electronic funds transfer (EFT).TEXNET, the State of Texas Financial Network, was designed to facilitate electronic payments from taxpayers and holders.

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Reconciliation of General Ledger Unclaimed Property Liability Account

At the conclusion of the reporting cycle, it is important to update accounting records to reflect the reporting of amounts as unclaimed property and properly reflect only what is due and payable in future periods.

This important step will reduce the likelihood of double reporting a property to the state.

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Establish Policies and Procedures

• Interview Process Owners

• Obtain Sample A/R aging

• Complete A/R questionnaire

• GL system review

• Verify unapplied cash practices

• Verify de minimis write-off practices

• Identify manual and automatic writeoffs (if any)

• Document A/R process; draft policy and procedures

• Setup A/R escheat liability GL account

• Augment policy and procedures for escheat best practices and compliance timeline

AR


• Obtain sample check register or outstanding checklist and void reports

• Complete A/P questionnaire


• Verify stale date and void practices


• Document A/P process; draft policy and procedure

• Setup A/P escheat liability GL account


AP


• Determine if payroll done in house or outsourced (ADP)

• Obtain sample check register or outstanding checklist and void reports

• Complete payroll questionnaire


• Verify stale date and void practices


• Document payroll process; draft policy and procedure

• Setup payroll escheat liability GL account

• Augment policy and procedures for escheat BPs and compliance timeline

Payroll


• Complete TPA Matrix

• Obtain TPA Plan Documents

• TPA Confirmation Affidavits



• Document TPA process; draft policy and procedure

• Setup TPA escheat liability GL account


TPA

Questions?

Biographies

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Biography Joseph Carr, J.D.

Partner & National Unclaimed Property Practice Leader BDO USA, LLP 330 N. Wabash, 32nd Floor Chicago, IL 60611 Direct: (312) 616-3946 Cell: (773) 544-5150 [email protected]

With 16 years of combined experience in state and local taxation, financial statement auditing, and operational auditing, Joe has worked with a broad range of the Firms’ largest clients including manufacturing, retail, distribution, financial institutions, investment companies, and business services. He specializes in state and local tax issues with an emphasis on income/franchise taxation and unclaimed property compliance and consulting.

Joe heads up the firms National Unclaimed Property practice and has had success in mitigating client escheat exposures in VDA and audit settlements before many state escheat divisions. This success is largely attributable to his deep understanding of accounting principles, transaction flow and unclaimed property law. Having evaluated financial and operational corporate risks, Joe offers clients facing escheat issues valuable accounting experience and an unique perspective in dealing with unclaimed property matters. Mr. Carr has also written various alerts and firm bulletins on unclaimed property matters, including gift card planning and strategies.

Prior to joining the Chicago office of BDO USA, LLP, Joe worked with KPMG LLP and Deloitte & Touche LLP in state and local tax and audit divisions respectively. In addition, Joe also managed the Internal Audit Division of a middle market food cooperative.


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Biography Ricardo Garcia

Senior Director West Coast Unclaimed Property Practice Leader BDO USA, LLP, Costa Mesa 3200Bristol St., 4th Floor Costa Mesa, CA 92626 Direct: (714) 668-7308 Cell: (323) 715-4406 [email protected]

Ricardo has over 10 years of experience advising multinational and domestic companies on unclaimed property matters. Ricardo has provided clients with unclaimed property general consulting, audit defense, and compliance services in many industries including healthcare, manufacturing, entertainment, and retail. As the firm’s West Coast Unclaimed Property Practice Leader, Ricardo has established professional relationships with many of the state unclaimed property administrators in handling client matters, and has successfully negotiated voluntary disclosure agreements on behalf of clients and provided audit representation services. In addition, Ricardo has significant escheat planning experience and has helped many clients mitigate exposures through intercompany planning techniques and strategies. Prior to joining BDO, Ricardo worked with Ryan, Inc. and True Partners Consulting in their unclaimed property consulting practice.

http://www.linkedin.com/profile/edit-picture-info?goback=.npe_*1_*1_*1_*1_*1_*1&trk=nprofile-edit-picture-info

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Biography Augusto Conde III, CPA

Manager Unclaimed Property Practice BDO USA, LLP, Costa Mesa 3200 Bristol St., 4th Floor Costa Mesa, CA 92626 Direct: (714) 338-2547 Cell: (562) 883-0444 [email protected]

Augusto comes to BDO with 8 years of experience advising multinational and domestic companies on unclaimed property matters. Augusto has provided clients with unclaimed property general consulting, audit defense, and compliance services in many industries including healthcare, manufacturing, entertainment, and retail. Augusto has assisted in the successfully negotiation of voluntary disclosure agreements on behalf of clients and provided audit representation services. In addition, Augusto has significant escheat planning experience and has helped many clients mitigate exposures through intercompany planning techniques and strategies. Prior to joining BDO, Augusto worked with PwC and Ryan, Inc. in their unclaimed property consulting practice.

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: www.bdo.com. Material discussed is meant to provide general information and should not be acted on without professional advice tailored to your firm’s individual needs. © 2015 BDO USA, LLP. All rights reserved.