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STATE & LOCAL TAXES




                                                                             ■   Not having tax approve each
                In addition to sampling methodology,                           request, just the material impact,
                                                                               and/or perform a cadence review of
               technologies such as robotic process                            what has been issued.
             automation; extract, transform, and load;                       ■   Educating purchasers throughout the
               and optical character recognition have                          organization of use tax basics, if pos-
                                                                               sible, including a high-level matrix
                     become common audit tools.                                decision tree of when to provide a
                                                                               vendor certificate during purchases.
                                                                               Similar to a proactive cadence review
         and/or ERP are then updated to reflect   because it was sent to an email   of vendor certificate issuance, an auto-
         that customer exemption.            address of the seller — it more than   mated comparison of exempt sales to
           Assume that three to four years   makes up for the manual hours spent   customer certificates is also a key meth-
         later the business is defending this   declining and validating revised   od of examining risk. Leveraging citizen
         exempt transaction under audit. While   certificates.               automations (i.e., strategies developed by
         you may be able to summarize the   ■   Accept a certificate in good faith   nontechnical business users), such as the
         overall customer certificate process in   — in most states, the taxpayer is not   ETL tools mentioned above, can quickly
         just a few sentences, validation and   obligated to do in-depth research on   create a reconciled file between exempt
         maintenance can result in thousands   the customer to determine how they   sale customer names and certificate cus-
         of manual hours each year, even when   are registered; instead, it can accept   tomer names.
         leveraging technology. Tools in the   the certificate in good faith.   If the record systems are not clean
         market can streamline the process for   ■   The business also is not required to   enough to create a straight match of
         both customer certificate collection and   research whether the signer of the   names, fuzzy matching is a great capa-
         vendor certificate issuance. However,   certificate is in fact an officer, direc-  bility within many ETL tools that can
         few organizations have fully integrated   tor, or another person authorized to   help to match similar, but not identical,
         these solutions into their ERP and tax   sign it. Instead, the signature can be   names. Ideally, the business will want to
         engine to make the most of the experi-  accepted in good faith.     work with its IT department to capture
         ence, resulting in the need for manual   In addition to addressing the human  the correct matching datapoints to tie
         processes. So how do you address it?   element of the validation process for   out customer information between sales
           Aside from technology, the first area   customer certificates, the issuance   data and exemption certificates — both
         to examine is how the team is validat-  of vendor certificates also can create   to streamline the proactive comparison
         ing certificates. There are two possibili-  problems when under audit. While the   in seeking to ensure certificates are on
         ties: Either there is minimal validation,   business often does not need to pro-  file for exempt sales and to retrieve
         which results in customers uploading   vide this proof of documentation, an   certificates for audit documenta-
         their grocery list (often not accepted   unstructured vendor certificate process   tion support.
         by auditors), or the team is validating   can result in local stores, business units,
         every aspect of the certificate, spending   or factories providing a certificate to   Exactly what are ‘audit-ready
         two or three hours researching just one   purchase goods and services without   files’?
         customer and declining their certificate   tax when tax should have been paid.   You likely have heard about “audit-
         because of a missing/wrong “issued to   The tax department may notice no tax   ready files.” Building on the use of citi-
         seller” address.                  was paid and accrue use tax — or it   zen automations and software systems
           The hours can quickly add up and   could go unnoticed and then result in   to handle big data and appropriate
         may require hiring three full-time re-  significant tax, penalties, and interest   methods to address common issues
         sources just to validate certificates. The   under audit.           regarding exemption certificates, other
         fastest way to address this is by follow-  Some best practices include:  considerations can help businesses
         ing a few simple rules:           ■   Establishing a centralized process   respond to stacks of audit notices.
         ■   Make the business decision to accept   for requesting vendor certificates   Cadence is a priority here; it is more
           certificates that are missing the   through a workflow management   important to have a realistic process in
           issued-to-seller information. This   tool, many of which are readily   place. Here are suggestions to create
           requires proactively working with   available through the organization’s   a process that can result in files ready
           auditors to accept the certificate   IT group.                    to audit:



         56  March 2023                                                                       The Tax Adviser
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