One of Commissioner Pitter’s first efforts under DOR360 – an initiative launched to enhance communications throughout the DOR community – was to understand the 355U filing process for combined reporting from the perspectives of taxpayers and practitioners.  A group of taxpayers with combined reporting experience joined forces with representatives from DOR’s Audit, Legal and Communications divisions to develop a survey for taxpayers and practitioners to provide us with feedback.  The survey was initiated earlier this year, and sent again after the October filing, resulting in thoughtful feedback on the filing process.  Separately, the major software vendors provided their perspectives.

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As a result of what DOR learned, changes will be implemented for the 2013 filing of Form 355U and they are detailed below.

CHANGES FOR THE 2013 FILING OF MA DOR FORM 355U 
for Combined Reporting

SCHEDULES TO BE ELIMINATED FOR 2013 FILING

  • Schedule CD
  • Schedule F2
  • Schedule U-DRD
  • Schedule U-NI
  • Schedule E-2 (a revised Schedule NOL, for all corporate filers, will be filed in its place)
  • U-NOL (a revised Schedule NOL, for all corporate filers, will be filed in its place)

SCHEDULE TO BE MODIFIED FOR 2013 FILING
Schedule FE – will allow data to be transferred from IRS Form 5471 

The draft 355U Schedules, with highlighted changes, may be viewed on the DOR Website

OTHER CHANGES FOR 2013 FILING

  • ERROR MESSAGES: Unique sequence numbers will be added to identify schedule and line if rejected on e-file.
  • The 52-53 reporting method will be functional for all 52-53 week years – e.g., Taxpayers with a 52-53 week year that begins in late December will not be forced to enter January 1 as the period start date. 
  • It will be possible to report 2014 short year returns on 2013 forms. 

FORM INSTRUCTIONS
There will be some enhancements to the instructions on forms for greater clarity.

COMBINED REPORTS FOR PRIOR TAX YEARS

A taxpayer filing or amending a combined report for tax years for which electronic filing is no longer supported by the taxpayer’s software vendor will be permitted to file for those tax years on paper. See DOR’s .

DOR will follow up to ask for feedback from taxpayers and practitioners after the 2013 filing.

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