Is your company incorporated or formed in Wisconsin or has a physical presence in the State? If Yes, Wisconsin’s unclaimed property Voluntary Disclosure Program (“VDA”) is applicable to you, but you need to act quickly as the deadline to sign up is quickly approaching.
What is Wisconsin’s Unclaimed Property VDA Program:
It is a one-time program offered by the Wisconsin legislature to allow non-compliant companies the opportunity to voluntarily gain compliance with the State’s unclaimed property filing requirements. The limited program commenced on February 1, 2022, and the deadline to sign-up is February 28, 2023. You then have up to 120 days to complete the unclaimed property review and filing.
What is Unclaimed Property?
Any obligation a Company owes to its employees, vendors, customers, state agencies or shareholders. The obligations may be in the form of: (i) uncashed checks; (ii) voided checks used to reverse liabilities for amounts owed by the company; (iii) customer overpayments; (iv) duplicate payments; (v) customer refunds; (vi) credit balances; (vii) unapplied cash; (viii) unidentified remittances; (ix) uncashed rebate checks; as well as (x) write-offs to income of amounts owed by the Company to 3rd parties.
What are Wisconsin’s Unclaimed Property Filing Requirements:
Wisconsin’s unclaimed property law requires companies to report and remit all liabilities, such as set forth above, to the State if there has been no activity or contact with the owners (employees, vendors, customers or shareholders) within 1 year for payroll and 5 years for all other property types. Unclaimed property reports are required to be filed annually with the State, including negative or zero reports if no amounts are owed for a specific filing period.
What Companies Can Benefit From the VDA?
Any company with obligations that are owed to individuals, other companies or governmental agencies with addresses in Wisconsin, especially companies incorporated, formed or have a physical presence in the state that are not in compliance with the State’s unclaimed property reporting requirements. Is your Company in compliance?
What are the Benefits of the VDA Program:
If your company is not in compliance, the VDA allows you to gain compliance without the imposition of late fees , interest or penalties. Further, unlike unclaimed property audits that reach back as far as 15 reporting periods or longer, the Wisconsin VDA requires the identification of property for only the most recent 5 reporting periods.
What are the Eligibility Requirements To Participate in the VDA Program:
Your company has not been audited for unclaimed property since July 1, 2016 and does not have a balance due on its Wisconsin’s unclaimed property company account.
Clarus Partners Unclaimed Property Team:
To determine how best to take advantage of this one-time voluntary VDA program offered by the State of Wisconsin, contact Partner, Sonia Walwyn at [email protected] or (630) 216-9954 to discuss how to assess your Wisconsin compliance risks, secure the benefits of the VDA through voluntary compliance, and maintain timely compliance prospectively to avoid unclaimed property state-initiated audits.