Comments on FTPBP #4 - 2018
Jurisdiction Position Comments

ALABAMA
Undecided Alabama supports a firm cut off date.  In today's electronic world, the amount of time needed to post tax rate changes seems excessive.

ALBERTA
Undecided Alberta generally supports the ballot and a firm cut-off date.  However, we also recognize that there may be extraordinary circumstances.  We are not sure providing another 5 days will help.   

BRITISH COLUMBIA
Support This ballot is intended for the convenience of jurisdictional staff, IFTA carriers and service providers/tax preparers.  It is not intended to limit the ability of any jurisdiction to set or change their tax rates.  It is intended only to limit communication of a late tax rate change to others (i.e., those outside the jurisdiction making the late change) after a specific cut-off date.  
 
Jurisdictions have different internal timelines and processes and some can make accomidate rate changes later than others but each time a late rate change is communicated outside the jurisdiction making the change there is an increased risk of inconsistency and additional work created for other jurisdictions and their IFTA carriers.  As an example:
  • Jurisdiction A - communicates a late tax rate change outside their jurisdiction.  Jurisdiction B & C – do not have sufficient time to accommodate the change in their IFTA systems.
  • However, a number of IFTA carriers within Jurisdiction B & C and service providers/tax preparers for IFTA carriers in Jurisdiction B & C are able to accommodate the late change.
  • This results in those IFTA carrier’s submitting returns to Jurisdiction A & B going into error (the amount due on a licensee’s tax return differs from what the jurisdiction’s financial system calculates) and needing to be manually processed, and potentially amounts written-off, and/or assessments/refunds issued.

CALIFORNIA
Oppose We already have a firm cutoff date and we still have jurs missing it.  They can always ask jurs to change the rate after the cut off but jurs have no obligation to change the rate after the existing firm cutoff date.

CONNECTICUT
Undecided

IDAHO
Support

KANSAS
Support

MAINE
Undecided

MANITOBA
Support

MARYLAND
Undecided Maryland will likely support Ballot #4- 2018.    We would like to comment, however, that this initiative seems to be at the convenience of Jurisdiction staff rather than the overall IFTA Objective, where accuracy of rates would take priority over the convenience,   Maryland can accomodate rate changes up to two (2) days prior to the 15th day, when blank paper returns are cut.  Although Maryland has never had a need to submit a late rate, we readily accomodated other Jrusidiction late rate changes whenever possible in an effort to make the rates on in our system as accurate as possible.   We recognize that other Juris may not have this type of flexibility.

MICHIGAN
Support

MISSISSIPPI
Support

MONTANA
Support

NEBRASKA
Oppose I don't see how adding 5 days is going to prevent the occasional occurrence of a jurisdiction that fails to notify IFTA, Inc. timely of a rate change.  Understanding that not all jurisdictions can accommodate late changes, it is still our belief that the core mission of IFTA is to properly collect fuel tax and jurisdictions should do everything in their power to collect at the proper rate and IFTA, Inc. should do everything in their power to assist in that endeavor.

NEVADA
Support Nevada supports a firm cutoff date. 

NEW BRUNSWICK
Support

NEW HAMPSHIRE
Oppose

NORTH CAROLINA
Oppose

NOVA SCOTIA
Support

OKLAHOMA
Oppose This ballot looks like an attempt to prevent jurisdictions from implementing a tax rate change that wasn’t communicated within the timeframe required by P1120.  If the jurisdiction is able to implement the change, why not allow them to? What harm has occurred that should prevent the repository from communicating late rates to the jurisdictions?

ONTARIO
Oppose ON is a jurisdiction that has very little leeway in allowing for late tax rate changes due to a continued reliance on paper based returns – consequently we are not usually able to accommodate most requested revisions. Despite that, considering that a licensee may still be liable for tax owing to the requesting jurisdiction, we would not be comfortable in foregoing the corresponding notification as we purposely publicize such information to ensure the ON licensee is made aware of the potential for an ensuing tax assessment.

From the ON perspective, reducing the window from 60 days to 55 days would not help improve the ability to react to a late rate change and the efforts to amend the provision seem to be out of proportion to the possible benefit.

 

PRINCE EDWARD ISLAND
Undecided Although we can accommodate short turnarounds, we appreciate not all jurisdictions have that luxury, which we believe was covered by the extraordinary measures clause.  If the ballot passes, future cleanup to the wording should consider "will not be communicated to member jurisdictions UNTIL THE FOLLOWING QUARTER" or words to that effect.  As well, the first sentence of .300 can be removed entirely.  PEI will follow the comments on this ballot before deciding our final position.

QUEBEC
Oppose Comments from the legal department: This proposed amendment could be interpreted as limiting the sovereign power of each jurisdiction to set its tax rates. We believe that the current version of P1120.100 and P1120.300 should be retained to allow jurisidictions that can accommodate another jurisdiction for a rate change after the deadline set by IFTA, Inc. to do.

RHODE ISLAND
Oppose

SOUTH CAROLINA
Support

SOUTH DAKOTA
Undecided

UTAH
Oppose We already have a firm cutoff date.

VIRGINIA
Undecided

WASHINGTON
Support

WEST VIRGINIA
Undecided

WISCONSIN
Undecided

WYOMING
Support
Support: 13
Oppose: 9
Undecided: 10
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