Application for Common Paymaster (Florida Form RTS-70)

What is Florida Form RTS-70?

Form RTS-70 is the Application For Common Paymaster of the Florida Department of Revenue. The Department's file is marked "RTS-70" and "R. 06/21".

The form defines the term: "A common paymaster is any member of a group of related corporations/limited liability companies (LLCs) treated as corporations for federal income tax purposes that disburses wages to concurrent employees on behalf of the group."

The address of this page calls the document an agreement. The Department's form is an application, and it warns: "An agreement between corporations/LLCs, where one corporation/LLC agrees to consolidate the payroll of the group for reemployment tax (formerly unemployment tax) purposes, does not qualify the group for common paymaster. That is considered payrolling and is not allowed in Florida."

Which groups can apply?

The form lists the conditions "To qualify as a group for reporting under a common paymaster":

• "All entities must be corporations/LLCs."
• "All corporations/LLCs must be employers."
• "All corporations/LLCs must be related."
• "There must be concurrent employment between the proposed common paymaster and all the related corporations/LLCs."

The form prints four tests of when corporations or LLCs are considered related and asks the applicant to check one of them. It gives the definition of concurrent employment that it takes from the Florida Statutes: "the existence of simultaneous employment relationships between an individual and related corporations". It adds that concurrent employment "is subject to verification".

What is on the form?

The form has two pages.

• Information for the corporation or LLC "wishing to become the common paymaster for the group": the legal name, the mailing address, the place where payroll records are maintained, the telephone number, the FEIN and the reemployment tax account number.
• The four tests of a related group, each with a check box.
• A list of the related corporations or LLCs, with the reemployment tax account number and the legal name of each. The form says: "If the related corporation/LLC has not been assigned a reemployment tax account number, you must register each corporation/LLC not registered."
• A declaration: "Being authorized to execute this application on behalf of the corporations/LLCs named, and under penalties of perjury, I declare that I have read the foregoing application and that the facts stated in it are true." Under it are lines for the signature, the printed name, the date and the official position.

What is attached to the application?

The form says: "Attach a copy of the Employer's Quarterly Report (RT-6), most recently filed, for each company/LLC, showing wages for all concurrent employees." It adds: "If concurrent employment recently began, and wages were not included on a prior report, you must also complete and attach an Affidavit of Concurrent Employment (RTS-72)."

The Department's page on common paymasters adds: "Documentation to demonstrate corporate status and that at least one of the above four criteria has been met must be provided with the Application for Common Paymaster (Form RTS-70)." It also says: "A completed Florida Business Tax Application (Form DR-1) must be included for any applicant without an active Florida reemployment tax account."

The second page prints a return address of the Florida Department of Revenue and a telephone number for assistance.

What does the form say about approval?

The notes on the second page include:

• "The common paymaster status must be approved by the Department before you can begin reporting as a common paymaster."
• "Once approved, the effective date of the common paymaster status begins the first day of the quarter, following the date of the Department's approval letter."
• "Common paymaster status cannot be made effective retroactively."
• "All members of the group will be responsible for filing their own Employer's Quarterly Report (RT-6) for the quarter prior to the effective date."
• "Quarterly reports still need to be filed for each corporation/LLC to report any non-concurrent employees."
• "Each corporation/LLC must reimburse the common paymaster for the wages and payroll taxes paid on the corporation/LLC's behalf."

The Department explains common paymasters on its page Reemployment Tax Additional Topics and lists the form on its page Forms and Publications.