Holders may reach out to the State directly using the following contact information to ascertain eligibility status and/or inquire further about the VDA program:
KEANE”). In January 2022, Gary returned to DAS as Partner, and is responsible for the oversight of the program. During his time as a consultant, he provided various services to unclaimed property holders such as audit defense, Delaware Voluntary Disclosure Agreement (VDA) assistance, and pre/post M&A liability quantification and remediation. Also, as an active member of NADOA, Gary has presented at NADOA conferences and HADOA luncheons and assisted in updating the escheat module for CDOA certification. Gary’s twelve years of experience as an auditor/audit manager, advocate/consultant manager and Senior Manager yield a wide range and balance of unclaimed property compliance experience. This diverse knowledge and understanding of the state and holder “sides” of the equation yield DAS’s state clients and holders balanced, informed, fair, and reasonable audits as we navigate the ever-changing complexities of compliance enforcement and education.
Texas Comptroller of Public Accounts Holder Reporting Section P.O. Box 12247 Austin, Texas 78711
Holders can also forward their requests for participation via email to: UP.VDA.requests@cpa.texas.gov About The Author
Gary Joseph is a Partner at Discovery Audit Services, LLC (DAS). Gary began his career at DAS in 2010, where he became the Abandoned & Unclaimed Property
Audit Manager and was responsible for all technical and quality functions of the program. In 2017, he departed DAS to become an Unclaimed Property State & Local Tax Manager in BDO USA, LLP’s Houston office, and later a Senior Consulting Manager for Sovos (“formerly
Contact info: Phone (346) 412 - 0021 Email gjoseph@discoveryauditservicesllc.com
Unclaimed Property Reporting By Paola Narez
Unclaimed property audits in the Oil & Gas industry have historically been a means by which states have generated additional revenue. This is not likely to change given that unclaimed property regulations continue to evolve, and States look to supplement budget shortcomings in the current economic environment. In addition to the standard general ledger property types, unclaimed property in the O&G industry can include unclaimed mineral proceeds, suspended royalties, storage or right- of-way payments, and account receivable joint interest billing (“JIB”) credits. No matter if you are upstream, midstream, or downstream – there is a need to comply with each State’s unclaimed property law as each sector has its own unique areas of exposure. For the reasons mentioned above, O&G companies should have a comprehensive, systematic means
to conduct annual review of accounting records to determine if they hold any property, whether tangible or intangible, that has remained unclaimed for the required dormancy period (typically one to five years, depending on the property type and jurisdiction). Although there are many unique differences and requirements among states, below are six unclaimed property reporting recommendations applicable to the oil and gas industry regardless of state jurisdiction: • File property to the correct jurisdiction .
The U.S. Supreme Court established two unclaimed property priority rules with its Texas v. New Jersey decision in 1965: First Priority Rule: Abandoned property must be escheated to the state of
24
N at i onal A ssociation of D i v i s i on O rder A nalys t s
Made with FlippingBook - Online catalogs