Last year Brad MacDougall, Vice President of Government Affairs for AIM (Associated Industries of Massachusetts), an association of Massachusetts employers, came to DOR on behalf of his membership with some concerns about the Form 355U, Combined Reporting Filing.  The members thought the forms were difficult to complete and wanted to see if we could collaborate on finding a solution.  This inquiry was not entirely surprising to DOR, given the complexity of the 355U reporting requirements.

Led by Senior Policy Advisor Dave Davenport, DOR put together a working group that included Dana Ackerman, Mike Fatale, Bill Graham, Maryann Merigan and Steve Moffatt.  They worked together with George Connor, Senior Tax Manager, EMC; John Griffin, Director, State and Local Tax, Millipore; Paul O’Connor, Head, US Tax Group, Millipore and Jaime Prudente, Tax Supervisor, EMC Corporation to create a survey to assess the experience of those who file Form 355U.  The survey asked about process, time, problem forms, and concluded by asking for general comments on the filings.

The respondents confirmed that the filing process took a lot of time and effort and was too complicated and confusing.  Some practitioners said that they put in lots of hours navigating the process that unfortunately could not be billed to clients.  There is a little sunlight from some of the respondents who reported that the process had gotten better each year. 

So, what is DOR going to do?  Plenty. Three forms will be eliminated before next year’s filing, a particularly difficult form will be simplified dramatically, instructions will be clarified on other forms and additional remedies are under consideration. After one of the final meetings, the group thanked DOR for listening and responding; one of the contributors even mentioned that he was happy to be walking into DOR on a non-adversarial visit!

DOR owes a debt of gratitude to AIM and the group from EMC and EMD for working together with us to get to the bottom of the 355U issues.  The process gave DOR insight from the taxpayer’s perspective and that is exactly what the Commissioner stated as one of her major goals in expanding communications through her DOR360 initiative.

The DOR working group also had invaluable assistance from DOR employees Jean Fairweather, Rosann Hansen, Vin Piccinni and Barry White.