United States

New York: Voluntary Compliance Program Reach Back Period Reduced from Twenty to Ten Years

Jan 16, 2017
From KPMG TaxWatch

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The New York State Comptroller has recently revised the reach-back period for unclaimed property holders that participate in the Comptroller’s unclaimed property voluntary compliance (“VCA”) program. Prior to January 1, 2017, holders were subject to a look-back period back to the 1996 report year. Under the new guidelines―applicable to enrollees in the voluntary compliance program after January 1, 2017―the look-back for general ledger property types (e.g., unclaimed wages, accounts payable checks, refund checks, merchandise credits, and gift certificates) has been shortened to report year 2007.

Organizations that hold unclaimed property but have not filed required reports, as well as those that have previously filed but did not report all property types are eligible to participate in the program. Benefits of participation include the elimination of interest or penalties and a shorter reach-back period than would be expected under an unclaimed property audit (the audit reach back period is to January 1, 1992 for General Ledger items). For more information on the reduced reach-back period and the New York voluntary compliance program generally, please contact Will King at 214-840-6107 or Pete Billows at 212-872-2921.


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The following information is not intended to be "written advice concerning one or more federal tax matters" subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.