Keane's Unclaimed Property Blog

Unclaimed Property Law (48 articles)

NAUPA Provides Guidance on IRS Revenue Ruling 2018-17

NAUPA Provides Guidance on IRS Revenue Ruling 2018-17

Compliance, Escheat Law, Unclaimed Property Law

Since its release in May 2018, IRS Revenue Ruling 2018-17[1] has raised significant legal and operational concerns for holders. Under the Ruling, the escheatment of an IRA to the state constitutes a designated distribution, subject to a 10% federal tax withholding. The trustee or custodian of the IRA must also report the designated distribution on a […]

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The Raw Data Analytics LLC Case May Change the Unclaimed Property Landscape and Liability for the Holder Community!

The Raw Data Analytics LLC Case May Change the Unclaimed Property Landscape and Liability for the Holder Community!

Compliance, Escheatment, Litigation, Unclaimed Property, Unclaimed Property Law, Unclaimed Property Reporting

Unclaimed property compliance has been on the rise since the early 2000s. Many companies are aware of state unclaimed property laws, programs, and annual filing requirements. State auditors, third party audit firms, and amnesty programs such as voluntary disclosure agreement (“VDA”) have also contributed to the increase in compliance. VDA programs allow companies to become […]

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The Times, They Are A Changing

The Times, They Are A Changing

Legislative Updates, Unclaimed Property Law

As increasing retirement savings continues to be a concern among Americans, will the rules surrounding unclaimed IRAs and 401(k) plans change? May 2018: IRS Issues Revenue Ruling 2018-17 Regarding Unclaimed IRAs The escheatment of an IRA account constitutes a designated distribution, subject to a 10% federal withholding. Trustees/custodians of the IRA must issue a 1099R […]

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Accounting for Unclaimed Property

Abandoned Property, Compliance, Unclaimed Property, Unclaimed Property Law, Unclaimed Property Reporting

Escheatment is the process of remitting an asset to the state of the address of record as unclaimed property. When not correctly managed and reported, the historic unclaimed property liability coupled with the risk of state audits – and subsequent fines and penalties for non-compliance – become material to your annual reviews, findings, and ultimate opinions. And, given the […]

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Gift Card Escheatment Laws

Abandoned Property, Abandoned Property Law, Compliance, Dormancy Periods, Escheat Law, Escheatment, Gift Card Escheatment, State Escheatment, Unclaimed Property, Unclaimed Property Law, Unclaimed Property Reporting

Update 2019: Are gift cards escheatable? Unfortunately, the answer is not simple as each state and territory have different unclaimed property laws regarding gift cards and the time before escheatment. These differences in state laws impact gift card breakage, the revenue companies gain through unredeemed gift cards. The Electronic Funds Transfer Act and the Consumer […]

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