managing sales tax data: streamlining internal...
TRANSCRIPT
Managing Sales Tax Data:
Streamlining Internal Controls
to Maximize Compliance Efficiency
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THURSDAY, FEBRUARY 20, 2014
Presenting a live 110-minute teleconference with interactive Q&A
Mike Dillon, President, Dillon Tax Consulting, Annapolis, Md.
Kenneth Stites, Principal, Stites Tax Consulting, Austin, Texas
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Managing Sales Tax Data: Streamlining Internal Controls to Maximize Compliance Efficiency
Michael T. Dillon, Dillon Tax Consulting
Feb. 20, 2014
Ken Stites, Stites Tax Consulting
Today’s Program
Sales Tax Data Requirements and Return Preparation
[Kenneth Stites]
Internal Controls and Audit Defense
[Michael T. Dillon]
Slide 8 – Slide 19
Slide 20 – Slide 37
Notice
ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY
THE SPEAKERS’ FIRMS TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY
OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT
MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR
RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.
You (and your employees, representatives, or agents) may disclose to any and all persons,
without limitation, the tax treatment or tax structure, or both, of any transaction
described in the associated materials we provide to you, including, but not limited to,
any tax opinions, memoranda, or other tax analyses contained in those materials.
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.
Sales Tax Data Requirements and Return Preparation
Kenneth Stites Principal at STITES TAX CONSULTING
(866) 705-6739
STITES TAX CONSULTING
www.stitestaxconsulting.com
Data Requirements for Sales and Use Tax Compliance
Sales Transactions and Exemption Documentation
Purchases of Fixed Assets
Purchases of Expense Items
STITES TAX CONSULTING
www.stitestaxconsulting.com 9
Sales Transactions
Required Data and Available Data
Summary data for sales with breakdowns by jurisdiction, taxable sales, exempt sales, tax invoiced
Transactions with unique tax calculations
Adjustments to sales amounts such as credit and debit memos
Journal entry detail for JE’s that affect recorded sales or recorded sales tax accrual
STITES TAX CONSULTING
www.stitestaxconsulting.com 10
Sales Transactions
Evaluating Systems that are in Place
Determine the systems that are collecting sales data, whether it be a module in the accounting software package or a separate billing software package or some combination of systems
Analyze system reports that are available and the potential for report customization
Consider data exports to spreadsheets to manage data in an efficient manner
Utilization of data stored by Sales Tax software package
STITES TAX CONSULTING
www.stitestaxconsulting.com 11
Sales Transactions
Access to and Maintenance of transaction detail
Copies of invoices retrievable by invoice number, customer name and date
Copies of credit memos that adjust sales amounts with reference to the original sales documents
Copies of contracts that provide definition of products or services
Journal entry back up for write offs that are processed
Exemption certificates
STITES TAX CONSULTING
www.stitestaxconsulting.com 12
Fixed Asset Purchases
Analyze or establish process to accrue and remit taxes on assets when necessary
Determine the dollar cutoffs with respect to items to be reviewed on an actual basis
Establish the process to be implemented to review fixed asset transactions for proper tax calculation
Develop a methodology to capture the tax due, accrue the tax on the books and report it on the sales and use tax return
Establish procedures for retaining detail for audit support
STITES TAX CONSULTING
www.stitestaxconsulting.com 13
Purchases of Expense Items
Establish a methodology for the review and reporting of expense items
Create and maintain a file of the invoices that are included in the use tax accrual
Develop a spreadsheet to accumulate data for the use tax accrual that documents methodology and assigns appropriate tax rates
Incorporate use tax calculation into compliance methodology
STITES TAX CONSULTING
www.stitestaxconsulting.com 14
Tax Return Preparation
Utilize summary data via system reports and prepared spreadsheets to prepare returns for filing.
Back end sales tax software can be used to generate returns, possibly facilitating direct uploads to the tax authorities.
Retain spreadsheets used to capture data from outside of the billing system, which is included on the tax returns.
STITES TAX CONSULTING
www.stitestaxconsulting.com 15
Tax Return Preparation
Create file for filed tax returns including copies of reports, spreadsheets, use tax back up, payment processing and mailing certification whether it is through the USPS or electronic.
Reconcile sales tax accrual account or accounts to the returns filed, adjustments and amounts that need to remain in the accrual.
STITES TAX CONSULTING
www.stitestaxconsulting.com 16
Data Validation
Confirm that established methodologies, strategies and processes are being followed. Perform transaction tests to determine that tax is calculated correctly, exempt transactions are excluded from the tax calculations and that transactions are properly recorded; also confirm that exemption documentation is properly maintained. Test the integrity of reports and spreadsheets used to complete the sales and use tax returns , for completeness and accuracy.
STITES TAX CONSULTING
www.stitestaxconsulting.com 17
Managing Sales Tax Data: Internal Controls
Training Staff in Data Management
• “Don’t know what we don’t know”
• Most companies lack tax process
• Most companies lack sales tax training
– So many variables that can affect tax decision or indecision
– No internal review or placed in hands of non-tax personnel
– Vendor incentive and A/P incentive
– Potential for overpayments as well as exposure
– Decentralized or complex sales and purchasing = more risk
20
Managing Sales Tax Data: Internal Controls
TRAINING STAFF IN DATA MANAGEMENT
• Understand the data they manage
• Communicate well with IT and IT systems
• Know how to get the data
• Know how to safeguard and validate the data
21
Managing Sales Tax Data: Internal Controls
Training Staff in Data Management
• Understand the data they manage
- Who, what, when, where, how
- Electronic processes – more detail is ideal
- Coding sales and purchase transactions to correct
jurisdiction, account, product and tax codes
- Tax matrix
- Rating
22
Managing Sales Tax Data: Internal Controls
Training Staff in Data Management
• Understand the data they manage
- Ensuring transaction details match contract and
invoice literals
- Coding sales and use tax to proper accounts
- Prepare back-up documents to support returns – audit
trails
- Reconciling tax accounts to ensure what was collected
and accrued was remitted
23
Managing Sales Tax Data: Internal Controls
TRAINING STAFF IN DATA MANAGEMENT
• Communicate well with IT and IT systems
- IT and data are critical to tax success
- What information exists, in what format
- What information tax needs to prepare returns and
maintain an audit trail
- Establish points of command for communication
between tax and IT
- Future IT needs of tax
24
Managing Sales Tax Data: Internal Controls
TRAINING STAFF IN DATA MANAGEMENT
• Know how to get the data
- Who, what, when, where, how fields
- Which systems have tax calculation data
- Which systems provide tax decision data
- Send data to CRM, OE or invoicing
- Query reports required to prepare returns
- Query reports required for audits
- Manual review of complex transactions
26
Managing Sales Tax Data: Internal Controls
TRAINING STAFF IN DATA MANAGEMENT
• Safeguarding and Validating the data
- Correct CRM / OE set-up
- Obtaining exemption and resale certificates
- Maintain tax matrix and audit issue resolution
- Detailed Reporting for audit purposes
- Departmental accountability for audit liabilities
- Manual review / intervention in processes
27
SALES AND USE TAX COMPL IANCE SOFTWARE
• Automated tax dec i s ion, rat ing and return
preparat ion
• Keep account ing personnel focused on h igher -
va lue work
• Data arch ived for aud i t purposes
28
Managing Sales Tax Data: Internal Controls
SALES AND USE TAX COMPL IANCE SOFTWARE: REQS
• Must cons ider and ensure seamless integrat ion
wi th account ing/b i l l ing p lat forms
• Even wi th automat ion, there i s human
i nvo lvement, which a lways leads to the
potent ia l fo r er ror.
– Minimize humans interaction but create reviews by tax for
select accounts, problem vendors, big purchases over
materiality threshhold
29
Managing Sales Tax Data: Internal Controls
SALES AND USE TAX COMPL IANCE SOFTWARE: REQS
• Systems must address who, what, when, where, hows
- More detailed descriptions reduce audit exposure
• Statutory exemptions must be addressed
• Exemption Certificate Management platforms
• Some purchases are exempt based on interstate commerce,
and consideration must be given to multiple jurisdictions and
when title is transferred.
30
Managing Sales Tax Data: Internal Controls
SALES AND USE TAX COMPL IANCE SOFTWARE: WHAT
SYSTEMS ARE AVA ILABLE
• Avalara
• Vertex
• Taxware
• BillSoft EZTax
• TaxAutomation and leading integrators can assist
31
Managing Sales Tax Data: Internal Controls
Obtaining “Buy-In” from the C-level suite
• Audit results are key driver
• Compliance Process Review
- Sales tax expert audits multistate nexus and compliance and
provides a gap and exposure analysis
- Report provides a “road map” for resolving historical exposure
and enhancing prospective compliance processes
• Cost comparison - manual versus automated compliance
• Cost of integration
32
Managing Sales Tax Data: Internal Controls
Pre-audit process
• Audit Risk = risk of inaccurate records + risk of misapplication
of the tax laws
• Review the audit information request to ensure:
- who, what, when, where, how – more detailed = better
– The information requested is relevant and available, and
available in the format requested
– If not, be prepared to discuss with auditor before initial
audit meeting and present alternatives
34
Managing Sales Tax Data: Audit Defense
PRE-AUDIT PROCESS
• Review the audit information request to ensure:
– Data fields not requested that will assist the audit process
(e.g., project codes; electronic delivery field)
• Audit Thyself - Review the items to be audited
- System walk-through
- Missing Certificates and Invoices
- Do transaction detail, register and returns reconcile
- Identify issues and prepare responses
35
Managing Sales Tax Data: Audit Defense
Audit process
• How are invoices and certs maintained – electronic v. manual
- Computer-assisted detail v. sampling – success depends on
quality of data and detailed descriptions
• Are there documents not requested that will assist the audit
process
- contracts and exhibits / addenda / SOWs
- accounting behind bundled or mixed transactions
• Consider system walk-through with auditor
36
Managing Sales Tax Data: Audit Defense