June 27, 2013
Mr. Craig M. Burns
Virginia Department of Taxation
P. O. Box 546
Richmond, VA 23218-0546
Via email: [email protected]
RE: Guidelines regarding Issuance of Debit Cards for Individual Tax Refunds
Dear Commissioner Burns:
The Tax Advisory Committee of the Virginia Society of CPAs (VSCPA) welcomes the opportunity to provide additional comments on the guidelines regarding the issuance of debit cards for individual income tax refunds as mandated by the 2012 General Assembly in HB 1301.
We understand that the majority of taxpayers that received a debit card refund during the recent filing season had no issues in transferring the funds to their bank account or in utilizing the card to make purchases. As with any new system, however, there were some isolated cases that were problematic.
As noted in our letter sent Aug. 2, 2012, the legislation provides that the Tax Commissioner may determine that a check is more appropriate for a transaction or class of transactions. We recommend reconsideration of the following such classes for the issuance of paper checks:
- Elderly taxpayers (perhaps those 65 and older) — most older taxpayers are not as familiar with the use of debit cards and may not have easy access to transportation to banking facilities
- Refunds in excess of $500 — larger refund amounts will increase the potential for fees and difficulties in negotiating the refund
- Taxpayers residing outside of the Commonwealth — such taxpayers may not have access to the preferred banks that will be permitted to negotiate the refunds without imposing fees (particularly those residing outside of the United States or serving in the armed forces)
We also recommend the implementation of a procedure to "opt out" of the debit card if it would cause undue hardship. For example, estranged couples often file joint returns to minimize their tax liabilities. In such cases, the refund checks are often deposited in the escrow account of their attorney pending settlement of the divorce proceedings.
As noted earlier, the Committee appreciates the opportunity to comment on this matter. We look forward to working collaboratively with your office to assist in any way.
The VSCPA is the leading professional association in Virginia dedicated to enhancing the success of CPAs and their profession by communicating information and vision, promoting professionalism and advocating members' interests. The VSCPA consists of more than 11,000 individual members who actively work in public accounting, private industry, government agencies or educational institutions.
Please feel free to contact me or VSCPA Government Affairs Director Emily Walker at (804) 612-9428 or [email protected] if we can be of further assistance.
Julia W. Rogers, CPA, CVA
Chair, Tax Committee
Virginia Society of CPAs
2013–14 VSCPA Tax Advisory Committee:
Julia W. Rogers, CPA, CVA — Chair
Nicholas Harrison, CPA — Vice Chair
Robert Baldassari, CPA
Rebecca Bartholomae, CPA
Alvin H. Carpenter III, CPA
Kenneth Dance, CPA
Damon DeSue, CPA
Duane Dobson, CPA
David Ellwanger, CPA
Ryan L. Losi, CPA
William C. Pilc, CPA
Kimberly A. Ruiz, CPA
Wayne E. Sine, CPA
Mark VanDeveer, CPA