Ryan previously reported that California established a voluntary compliance program (VCP) for unclaimed property for the first time since 2000. For California purposes, interest on past due property is assessed at 12% per annum, so this program has been eagerly anticipated by holders who want to get into compliance and have interest waived as part of the VCP.
Under guidance issued in March, the applicable dates for the initial enrollees in the upcoming report year were released as follows:
- July 31, 2023 – Required training to be completed
- September 30, 2023 – Due diligence to be completed
- Before November 1, 2023 – Notice report to be completed
- June 1–15, 2024 – Remit report and remittance to be submitted
However, participants applying for the program in July were recently presented with revised deadlines, as follows:
- October 12, 2023 – Required training to be completed
- December 12, 2023 – Due diligence to be completed
- January 11, 2024 – Notice report to be completed
- Between January 2024 and July 2024 – Respond to owner inquiries and reunite owners with property
- Between August 11, 2024 and August 26, 2024 – Remit report and remittance to be submitted
As this new timeline is presented for a specific application date, it appears that the timeline for applicants will depend on the date of application and acceptance into the program. This delay also indicates that the program may no longer be required to align with California’s annual dual reporting deadlines for unclaimed property. The traditional reporting period requires the notice report to be filed on or before November 1 and the remit report to be filed the following year between June 1 and June 15.
Please contact our Ryan professionals below who can assist you with all unclaimed property compliance issues.
TECHNICAL INFORMATION CONTACTS:
Mark A. Paolillo
Principal
Ryan
857.288.1976
mark.paolillo@ryan.com
Susan Han
Principal
Ryan
442.244.2447
susan.han@ryan.com
Jeff Henshall
Principal
Ryan
404.682.1200
jeff.henshall@ryan.com
Christopher Jensen
Principal
Ryan
469.399.4142
christopher.jensen@ryan.com
Sonja Roman-Molina
Principal
Ryan
954.740.6255
sonja.roman@ryan.com
The material presented in this communication is intended to provide general information only and should solely be seen as broad guidance and not directed to the particular facts or circumstances of any individual who may read this publication. No liability is accepted for acts or omissions taken in reliance upon the content of this piece. Before taking (or not taking) any action, readers should seek professional advice specific to their situation from Ryan, LLC or other tax professionals. For additional information about this topic, please contact us at info@ryan.com.