PCIAA’s William Stander Testifies on Insurance-Related Proposed Rules at Department of Revenue Workshop Today

Oct 11, 2010


At a Rule Development Workshop held today, October 11, 2010, the Florida Department of Revenue (“DOR”) heard public testimony regarding changes to various tax-related Rules, some of which relate to insurance.  Of particular concern to insurers are proposed Rule 12-24.003, entitled “Requirements to File or to Pay Taxes by Electronic Means,” as well as forms referenced by proposed Rule 12-24.011.  DOR officials Sarah Wachman and Janet Young served as moderator and presenter, respectively.  The Workshop agenda and proposed Rule texts are attached for review.

The above-referenced proposed Rules would require insurers that pay insurance premium taxes, fees and surcharges electronically to also file their insurance premium tax returns electronically. 

William Stander, Assistant Vice President and Regional Manager of the Property Casualty Insurers Association of America, testified at the Workshop, noting that, if adopted, these proposed Rules would cause a significant amount of time to be spent manually inputting premium tax figures into the required forms. 

Because of the voluminous entries that may be required of insurers, Mr. Stander also expressed concern for potential typing errors that could inadvertently create liability.  He recommended that the DOR consider a process whereby insurers could upload the figures electronically rather than manually input them.  It was noted that third-party vendors in other states provide this type of service, which should be considered for Florida. 

Following public testimony, Ms. Young stated that the DOR will consider alternative electronic data submission procedures before implementing these proposed Rules.  Meanwhile, current Rules will remain effective. 

Because there were no comments or concerns raised about any of the other proposed Rules on the agenda, they will proceed toward final adoption.  Other insurance-related proposed Rules considered today included:

  • Relating to Insurance Premium Tax and Florida’s Tax Credit Scholarship Program
    • 12-29.001: Scope
    • 12-29.002: Florida Tax Credit Scholarship Program; Participation; Allocation; Carryforward; Rescindment
    • 12-29.003: Florida Tax Credit Scholarship Program; Applications
  • Relating to Red Light Camera Penalty Payment Remittance

The record will remain open until October 22, 2010 for further written comments. 


Should you have any questions or comments, please contact Colodny Fass.



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