Sales & VAT Newsletter A Quarterly Publication of ADP’s Tax & Government Affairs Division

ISSUE 1/VOLUME 1 MAY 2011

ADP Extends its Sales In this issue: and Outsourced • Welcome to our first issue! Returns Solution Our enhanced Outsourced Returns • Affiliate Nexus: The Next Front in the State Battle Solution now interfaces with any to Tax Remote collection system and reduces By Charles Collins the burden associated with time- • Transaction Tax News from United States consuming tax filing processes. This powerful solution helps reduce • All EU-VATs Are Not the Same, and That’s OK operating risk and compliance By Richard Ainsworth costs, while freeing up resources • Transaction Tax News from Around the World for more mission critical tasks. • Sales Tax Holidays in the U.S. and Canada For additional details, please By Joan Howard see our press release: http://www.adp.com/media/press- • Tax Oddities Around the World releases/2011-news-releases/adp- extends-its-sales-and-use-tax-outso urced-returns-solution.aspx. Welcome to our first issue! Welcome to the first edition of the ADP Sales, Use and VAT Tax Solutions newsletter. In each issue, we will provide in-depth articles discussing topical issues in transaction tax, both in the US and globally.

In addition, we will provide short summaries of some of the most important legal and regulatory changes in tax laws that have taken place over the past quarter.

Our goal is to provide immediately useful information to transaction tax professionals while highlighting the interesting, challenging and sometimes comical application of these .

We hope you enjoy the newsletter. Please share it with all your colleagues!

Matthew Walsh Senior Director of Tax and Operations ADP Sales, Use and VAT Solutions

ADP SALES TAX & VAT NEWSLETTER 2 Affiliate Nexus: The Next Front in the State Battle to Tax Remote Sales

States’ efforts to increase compliance with their use tax laws are not new. States have historically educated, audited and legislated to collect more use tax. While states have increased collection of use tax, the growth of internet sales, and the continued inability of states to require remote sellers to collect the tax without a physical presence, has pushed the revenue loss from individual purchasers to an estimated $18B for 2012.*

During the past twelve months, states have refocused their legislative efforts to make it more difficult for remote sellers to ship products into their states without collecting tax. This increased focus should not be unexpected, as many state governments continue to deal with budget shortfalls. Simultaneously, instate sellers complain of being at a competitive disadvantage to remote sellers who are not collecting the tax. Charles Collins is Vice President of Government Legislation expanding nexus requirements has been enacted in New York, North Carolina and Rhode Island. These laws make the use of an instate affiliate Affairs at ADP. Prior to joining directing sales to an out of state remote sellers’ website a nexus, creating ADP, he spent 32 years activity for the out of state seller. This affiliate nexus is often referred to as with the North Carolina “click-through-nexus.” Other states have enacted special reporting or notice Department of Revenue. requirements on remote sellers, requiring them to inform the purchaser of He was Co-Chair of the their responsibility to self report the tax, and, in some states, a requirement on Streamlined Sales Tax the remote seller to provide the state a customer list of purchases shipped into Projects (SSTP) for two and a their state. half years, coordinated the During this legislative session, affiliate nexus, notice or reporting legislation is SSTP pilot project, and was very popular. Legislation has been introduced in sixteen states and has already also a delegate to the SST been enacted in Illinois and South Dakota. Remote sellers have contested the Implementing States. affiliate nexus laws and suits are pending in some states. Remote sellers have also severed ties with their instate affiliates in some states while they seek a judicial resolution.

According to published reports, states and main street retailers are continuing to push federal legislation to require remote sellers without a physical presence to During the past twelve collect sales and use tax. Although a bill has not been introduced, it is expected at any time. months, states appear to Internet sellers and other remote sellers should continue to monitor developments have refocused their efforts in the affiliate nexus and reporting areas at the state and federal level. Reserves legislatively to make it more may be necessary if a law change or court decision alters the current law. Failure to monitor the situation closely could put businesses in a non-compliant position. difficult for remote sellers to ship products into states without collecting tax.

* State and Local Government Sales Losses From Electronic Commerce by Donald Bruce, William Fox & LeAnn Luna, University of Tennessee, April 2009

ADP SALES TAX & VAT NEWSLETTER 3 Transaction Tax News from the United States

ALABAMA GEORGIA With a complex scheme of special rates applicable The state of Georgia became an associate to general rentals, linen rentals, motor vehicle member of Streamlined Sales Tax (SST) on rentals, manufacturing transaction, and agricultural January 1, 2011. As part of its SST legislation, sales, local rate changes in Alabama are generally Georgia implemented a number of law changes. far from newsworthy. However, a rate change in Most notably, the special local rates on food that Rainsville, AL (approximate population 4,500) applied in DeKalb, Muscogee, Rockdale, Taliaferro effective April 1, 2011 caught our attention. In and Webster Counties no longer apply. Food is implementing a new use , Rainsville decided now exempt at the state level and taxable at to make their agricultural and manufacturing use standard local rates. tax rates higher than the applicable sales tax rates , presenting a rather obvious constitutional concern. KANSAS Kansas was one of a number of states that COLORADO initially changed their local sourcing rules to In Colorado, the rules relating to the taxability of become compliant with the then existing software have been adjusted repeatedly over the Streamlined Sales Tax requirement of destination last few years. Current proposed legislation would sourcing. However, based upon a change in the reinstate, effective July 1, 2012 the significant SSTP requirements, Kansas is now debating a software exemption that was rescinded on May 1, legislative measure that would allow vendors 2010 in response to a server budget shortfall. to choose their sourcing methodology.

CONNECTICUT LOUISIANA The state’s legislature debated and the governor The Louisiana Department of Revenue temporarily signed into law bill SB 1239 that approved an suspended the effectiveness of two important overhaul reform of the states tax system. Among Policy Statements pertaining to the taxability of the changes approved are: the elimination of digital products and certain pay-per-view and multiple sales tax exemptions for goods and on-demand video services. The absence of services; an increase of the state sales tax rate these rules has created significant uncertainty to 6.35%; an increase of the hotel tax to 15%; the surrounding the taxability of these items. enactment and/or increase of taxes However, Louisiana has established a Working applicable to boats, clothing, jewelry, motor Group specifically tasked with bringing some vehicles and others, as well the requirement to clarity to this area. certain remote sellers with no physical presence in the state to collect the state sales tax. Other MASSACHUSETTS tax changes include the modification of personal As a result of a voter initiative, Massachusetts and corporate for the state. The has repealed its recently enacted sales tax on majority of sales and excise taxes change alcoholic beverages. become effective July 1 st , 2011.

ADP SALES TAX & VAT NEWSLETTER 4 MISSISSIPPI UTAH As it stands today, Tupelo is the only locality in Mississippi The Utah House has approved HB 35. If passed by the that imposes a sales tax. However, recently enacted SB senate and signed into law, the bill would significantly 2839 authorizes the city ofJackson to enact a 1% municipal change the taxability of products transferred electronically. sales tax if they so approve in a local election. VERMONT NEVADA There are bills pending that would reduce the state’s Aside from considering an expansion of their sales tax to sales tax rate from 6% to 4.5%, and extend that cover additional services, Nevada is also evaluating a tax to apply to candy and to a substantial number bill that would make water subject to tax. of services.

NEW YORK WEST VIRGINIA Effective April 1, 2011 the State of New York enacted an The state legislature approved a reduction to the tax rate exemption for the sale of clothing priced at $55 or less. applicable to food for home consumption from 3% to 2% This threshold applies to both the state level tax and the effective January 1, 2012. MCTD (Metropolitan Commuter Transportation District) tax. This replaces, at least temporarily, the $110 exemption OTHER NEWS: that was eliminated last year. Interestingly, the $55 Affiliate Nexus Laws: States considering legislation threshold applies to the MCTD tax in all counties that aimed at requiring on-line retailers to collect and impose the district tax. Under the old rules, the threshold remit tax include: Arizona, Arkansas, California, only applied to the MCTD in those counties that adopted Connecticut, Minnesota, New Mexico, Rhode Island, a threshold similar to the state. Tennessee and Vermont.

PUERTO RICO Streamlined Sales Tax Agreement: States considering legislation enabling membership into the SST agreement Puerto Rico has implemented a lottery system include: Florida, Hawaii, Massachusetts and Missouri. (IVU-Lotto) to encourage merchant compliance with their sales tax regime. Filers may be awarded cash and prizes.

SOUTH DAKOTA In conjunction with legislation that expands nexus requirements to include many on-line retailers, South Dakota has also enacted a bill requiring all out-of-state retailers without nexus to notify their South Dakota customers of their obligation to pay use tax on their purchases.

TENNESSEE Legislation making significant changes to Tennessee law so as to become compliant with the Streamlined Sales Tax Initiative is scheduled to take effect on July 1, 2011. As part of this change, the state would eliminate their secondary state tax on the amount of sales priced between $1,600 and $3,200. However, as has happened in the past, it is expected that the effective date for elimination of this tax will be delayed for another two years, keeping the secondary state tax in place.

ADP SALES TAX & VAT NEWSLETTER 5 All EU-VATs Are Not the Same, and That’s OK

You can be amazed at what you find for simple tax planning in a robust VAT software program. You could find a way to structure commercial leases in the EU without VAT. Sound too good to be true. It’s not, and the European Court of Justice (ECJ) has certified this result in at least one case, HMRC v. RBS Deutschland Holdings GmbH, C-277/09 , decided on December 22, 2010.

Certain commercial leases in the EU can take advantage of a lack of harmony in the place of supply rules among the Member States, and in doing so, construct commercial leases that are VAT-free. This is what the German subsidiary of the Royal Bank of Scotland did.

All the UK courts that heard the case agreed with the taxpayer, and now the ECJ agrees also. The VAT that was not collected on the leases was in fact not due .

The facts of the case are relatively straightforward. RBS Deutschland GmbH is a German subsidiary of The Royal Bank of Scotland plc. RBS Deutschland is established in Germany and registered for VAT in the UK as a “non-established taxable person.” RBS Deutschland purchases cars in the UK and then leases them to UK businesses. Employees of these businesses use the leased cars for business and personal purposes.

Richard T. Ainsworth is VAT is paid on the car purchases, and VAT is collected on the eventual disposition of Director of International the cars. However no VAT is collected on the intervening leases. The reason is a legal lacuna. As a matter of UK law, these leases are deemed to be supplies of services Government Affairs at ADP. [VATA, §5 (1) and Schedule 4, ¶ 1] that are taxable in Germany (the place where RBS He was formerly the Deputy Deutschland is established). Under German law however, these supplies are treated Director of the International as goods, and are considered taxable in the UK. Tax Program at Harvard Law School, a Lecturer in Law, Both Germany and the UK agree. VAT is due. The problem is the UK feels that and Adjunct Professor of German VAT is due; Germany feels that UK VAT is due. So, what’s a good lessor to do Public Policy at the Kennedy in this situation? Should RBS Deutschland comply with the letter of the law in both jurisdictions and collect no VAT at all? That’s exactly what they did! School of Government. Collecting both German and UK VAT is not an attractive option at 17.5% in the UK and 19% in Germany. That would not be good for business. Her Majesty’s Revenue and believed that if only one VAT is collected then it should be UK VAT. It also believed that if UK VAT is not collected then RBS Deutschland should not be entitled to a credit for the VAT paid on the purchase of the cars. It is easy to see why RBS Certain commercial Deutschland wanted to eliminate the VAT on these leases. Because of the mixed leases in the EU can take (business and personal) use of the cars, the firms leasing from RBS Deutschland could deduct no more than 50% of any VAT they paid. Effectively then, by discovering advantage of a lack a way collecting no VAT at all, RBS Deutschland gave its’ customers a full deduction. of harmony in the place This was very good for business. of supply rules among In short, there is a lacuna in the law, but it is one for legislatures, not the courts to resolve. Every business profile is different, so if you are not engaged in commercial the Member States. leases, the RBS Deutschland fact pattern may not be one you can duplicate. But you can find similar gaps in the EU’s VAT fabric either by contacting an experienced VAT advisor, or by exploring reasonable permutations of your standard business transactions in a robust VAT software system. The effort could well be worth the time.

ADP SALES TAX & VAT NEWSLETTER 6 Transaction Tax News from Around the Globe

European Union

CZECH REPUBLIC LITHUANIA The Czech Republic is considering delaying the The general VAT rate was increased to 22%, planned merger of their standard and reduced while the reduced rate applicable to books and VAT rates until 2013 as well, as the doubling of certain types of publications was raised to 12%. the VAT rate applicable to books to 20%. POLAND FINLAND Poland increased their standard VAT rate from The Finnish Tax Administration has announced 22% to 23% and approved a new super reduced that, effective April 1, a reverse charge rate of 5%. This new 5% rate applies to many mechanism, by which the buyer will be liable goods that previously were subject to a 0% or for VAT and not the seller, will be in effect for a 3% rate. certain construction services, including excavation, installation, finishing, and SLOVAKIA on-site cleaning work. The standard VAT rate was increased from 19% to 20%. However, the government has promised FRANCE that the 19% rate will be restored once deficit A new VAT Grouping regime was enacted in levels are reduced to less than 3%. France. Companies may be considered to be part of the same group when a parent company EUROPEAN COMMISSION owns 50% or more of the stock or the voting The European Commission has referred the rights of the affiliated company. The regime is Czech Republic, Finland, France, Greece, Italy, optional, but once elected, members should Poland, Portugal and Spain to the EU Court of remain part of the group for at least 2 years. Justice for failing to adopt the margin scheme required under Council Directive 2006/112w GREECE with respect to travel agents. In response, In January, the Greek parliament approved an most of the countries have made the necessary increase to the super reduced rate from 5.5% to adjustments to their local law. The Commission 6.5% and an increase in the reduced rate from is also considering new measures that would 12% to 13%. require member states that have a reduced rate for print media to apply that same reduced rate LATVIA for online media. Finally a new regulation was Latvia has increased their standard VAT rate approved to facilitate the implementation of from 21% to 22% and their reduced VAT rate certain provisions of Council Directive from 10% to 12%. 2006/112/EC relating to the application of place of supply rules for goods and services.

ADP SALES TAX & VAT NEWSLETTER 7 Europe (Non-EU) Americas

SWITZERLAND BARBADOS Effective January 1, 2011, Switzerland began Barbados has approved a temporary increase of the implementation of a new identification the VAT rate from 15% to 17.5% for a period of number regime for taxpayers. The new 18 months. The new rate was effective from numbers (UID) will replace the existing December 1, 2010 and is set to expire on taxpayer’s VAT registration number by January May 31, 2012. 2013. The new numbers follow the following permissible formats: CHE (followed by nine BRAZIL digits) (followed by either IVA, MWST, or TVA). The enactment of ICMS Protocol No. 21/2011 in Brazil is generating a lot of controversy, since it UKRAINE is changing the place of supply rules applicable A new Tax Code approved by the Verkhovna to the state level VAT which is locally known as Rada (Parliament) of Ukraine was signed into ICMS. Thus far, the ICMS had been applied law. It provides for a reduction in the standard using an origin basis. That is, sales through the value added tax rate from 20% to 17%, effective internet, telemarketing and showrooms were January 1, 2014. Until January 1, 2014, the subject to tax in the state where the seller is standard rate of 20% will remain unchanged. located. ICMS Protocol No. 21/2011 has changed these rules to make these transactions taxable in the state where the customer is Asia located. Those arguing against this change consider it to be a violation to the constitutional rules that implemented the ICMS. FIJI Effective, January 1, 2011, the standard VAT rate NETHERLANDS ANTILLES was increased from 12.5 to 15%. With the formal dissolution of the Netherlands Antilles in 2010, the islands Bonaire, Sint JAPAN Eustatius and Saba became special municipalities There is a debate on whether to increase the of the Kingdom of the Netherlands. In these from the current rate of new jurisdictions, new VAT systems have been 5% continues. enacted. On the island of Bonaire the tax is levied at 8% while in the islands of Sint SRI LANKA Eustatius and Saba, the rate is 6%. Effective January 1, 2011, the increased rate of 20% that applied to financial services was eliminated and replaced with a 12% rate.

ADP SALES TAX & VAT NEWSLETTER 8 The 2011 Tax Holiday Season

Even in these tough economic times, US 2011 SALES TAX HOLIDAY MAP states are continuing to jump on the sales tax holiday bandwagon. The holiday phenomenon started with New York in the late 90’s and its popularity continues to grow.

These holidays provide a jurisdiction with the ability to temporarily suspend the imposition of its sales tax, making them immensely popular with legislators, retailers, and the shopping public. However, they are not necessarily popular with tax professionals facing the daunting task of temporarily adjusting their standard tax processing, especially considering that the scope of these holidays can vary greatly. Schedules Sales Tax Holiday Tax Holiday Under Consideration While some states have holidays that No Sales Tax Holiday STH in 2010 but not in 2011 encompass virtually all retail sales, others limit their holidays to very or the intrinsic satisfaction of not Finally, due to the complexity of specific items including clothing, paying the government its share, administration, the concept of sales school supplies, computers and is a question of continued debate. tax holidays is not generally seen in software, hurricane preparedness Interestingly, while sales tax holidays jurisdictions such as Europe and supplies, EnergyStar certified items, significantly reduce state sales tax most of Canada, where value added and hunting supplies and firearms. revenue, those losses have in the past taxes apply. By definition, Sales Tax Usually, a specific dollar amount been reported to be at least partially Holidays are generally limited to those threshold applies. offset by increases in corporate jurisdictions that apply standard income and/or meals tax collections. sales tax principles. Shoppers unquestionably find something enticing about being able ADP’s tax solutions provide Finally, be aware that in addition to to buy items tax-free. Whenever a state comprehensive coverage with respect the enacted sales tax holidays included enacts their first sales tax holiday, to sales tax holidays, including a in the chart above, please know that stores will almost always be swamped. product taxability matrix that ADP is tracking active sales tax holiday Whether this “frenzy” is a result of addresses virtually every type of legislation throughout the US, including impulse buying, customers delaying product which may fall within the but not limited to: Florida, Illinois, necessary purchases until the holiday, scope of a sales tax holiday exemption. and Massachusetts.

Joan Howard is a Senior Tax Attorney in the the public sector, as a Sales & Use Tax Auditor Tax and Government Affairs Department at for the City of Boulder, Colorado, and was a ADP. She is responsible for researching Consultant in the State & Local Tax Group at transaction tax laws in the U.S., Canada and Ernst & Young. She is a graduate of Stonehill other foreign countries, including those within College and New England School of Law, and the EU. Joan has been with ADP since May of is a member of both the Massachusetts and 2003. She has transaction tax experience in New Jersey Bar.

ADP SALES TAX & VAT NEWSLETTER 9 2011 Sales Tax Holidays at a Glance

ENACTED FOR IMPACT ON STATE ITEMS COVERED 2011 (AS OF LOCALS* APRIL 2011)

Alabama Clothing, Computers/Software, School Supplies & Books August 5 - 7 Optional

Clothing, Clothing Accessories or equipment, School Supplies & Arkansas August 6 - 7 Mandatory School Instructional Material

Connecticut Clothing August 21 - 27 N/A

Iowa Clothing August 5 - 6 N/A

Louisiana Hurricane Preparedness Supplies May 28 - 29 Optional

All tangible personal property for non-business use, except Louisiana August 5 - 6 Optional motor vehicles and food for consumption within the premises.

Maryland Clothing August 14 - 20 N/A

Maryland ENERGY STAR Qualified Products Feb. 19 - 21 N/A

Mississippi Clothing July 29 - 30 Optional

Missouri ENERGY STAR Qualified Products April 19 - 25 Optional

Clothing, School Supplies, Computers/Software & Peripheral Missouri August 5 - 7 Optional for Personal Use

Clothing, Computers/Peripherals, & School Supplies. Optional to New Mexico August 5 - 7 Subject to Retailers Discretion the RETAILER

Clothing, School Supplies/Instructional Materials, Sports/Rec. North Carolina August 5 - 7 Mandatory Equipment, Computers/Peripherals

North Carolina ENERGY STAR Qualified Products Nov. 4 - 6 Mandatory

Oklahoma Clothing August 5 - 7 Mandatory

Clothing/Accessories, School Supplies, Computers for Personal Use & South Carolina August 5 - 7 Mandatory Software/Peripherals when Sold in Conjunction & Linens

Tennessee Clothing, School Supplies & Computers August 5 - 7 Mandatory

Texas ENERGY STAR Qualified Products May 28 - 30 Mandatory

Texas Clothing & School Supplies August 19 - 21 Mandatory

Virginia Hurricane Preparedness Equipment, including Portable Generators May 25 - 31 Mandatory

Virginia Clothing & School Supplies August 5 - 7 Mandatory

Virginia Home ENERGY STAR & Water Sense Qualified Products October 7 - 10 Mandatory

Puerto Rico Clothing, Computers/Software, School Supplies & Books July 15 - 17 Mandatory

Mandatory for Puerto Rico Supplies Needed in Cases of Natural Disasters Varies ** certain locals

* STHs may or may not include the sales taxes applied at city and other local levels. ** This STH in PR will apply when the state of emergency is issued in the island and will apply in the zones specified by the Treasury Department.

ADP SALES TAX & VAT NEWSLETTER 10 Fun and Interesting Tax Facts

Don't say you didn't know you were spinning in a carousel: Quiz yourself The Dutch tax administration has posted an announcement on its website warning Dutch businesses that participation in 1. How many states have local sales taxes in carousel fraud, even inadvertently, can be met with “unpleasant addition to the state sales taxes? consequences.” All riders on the carousel may subject to A. 32 B. 44 C.50 prosecution, even if they did not know they were spinning.

You tax us, and we will curse you: When the Romanian 2. Number of states without state sales taxes: Congress imposed a law that subjected income earned by witches A. 0 B. 5 C. 10 to tax last January, a coven of the new taxpayers gathered on the country's southern plains and along the Danube River to 3. Last state or US territory to adopt a sales tax cast spells on those congressmen who voted in favor of the was______, in: measure. The witches also cast spells on the Romanian President as punishment for signing the law into effect as well as upon A. 2006 B. 2007 C. 2002 the many tax officials who will ultimately enforce the law. As a precautionary measure, more than a few government officials, 4. The first state to adopt a sales tax was have taken to wearing the occasional purple garment which, ______, in: according to legend, has the power to ward off evil. A. 1956 B. 1945 C. 1921 Your Tax or Your Dog: The Swiss village of Reconvilier has informed those dog owners who are delinquent in paying their 5. The state with the highest state sales tax rate is annual pet tax that their dogs will be “sent to a farm upstate” ______with a state sales tax rate of: unless the tax is paid forthwith. A. 11% B. 9.44% C. 8.25% No Fancy Spending for Tax Evaders: In Taiwan, individuals who owe more than TWD $10 million in tax have been notified by the 6. Number of states that are associate members government that they are hereby forbidden to make any fancy of Streamlined Sales Tax: or extravagant expenditures until such time as their outstanding A. 5 B. 3 C. 4 liability is addressed. According to the government, “fancy spending” could include a number of things, even just splurging 7. Number of states with origin-based sales taxes: for a taxi ride. Evaders will be monitored and could face possible A.7 B. 11 C. 9 detention if this order is violated.

Far Out Tax Ideas: Collecting taxes on real property, motor 8. Number of countries that have a VAT: vehicles, and personal property is a time honored and down to A. 96 B. 68 C. 27 earth tradition. But trying to collect property taxes on things located in outer space is nothing but – innovative. With the final frontier in mind, Los Angeles County Assessors are trying 9. The country with the highest VAT standard rate to collect on the satellites orbiting above is ______. And that rate is: Los Angeles. A. 20.00% B. 25.50% C.25.00%

Up in Smoke: Federal and State tax officials are currently auditing the compliance of medical marijuana dispensaries in several states. Over the last few years, the legal sale of marijuana has grown exponentially in states like California

and 13 others where cannabis can be sold legally for medical B . 9 A . 8 B . 7 C . 6

C , a i n r o f i l a C . 5 C , a i n i g r i V t s e W . 4 A , o c i R o t r e u P . 3 B . 2 A . purposes. Naturally, tax officials want to ensure that these 1

: s r e w s n burgeoning businesses pay their fair share. A

ADP SALES TAX & VAT NEWSLETTER 11 Automatic Data Processing, Inc. 11 Northeastern Avenue Salem, NH 03079 Phone: 603-870-3700 Fax: 603-870-3730 On the web at: adp.com

Bob Levis Division Vice President/General Manager Mathew Walsh Senior Director—Operations

NEWSLETTER COORDINATORS Charles Maniace Manager—Tax Research Ramon Frias Tax Research Associate Monica DellaPorta

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