Dept of Talent & Economic Development v. Great Oaks Country Club

Summary

The Michigan Supreme Court held that a professional-employer-organization client qualifies for the new-employer unemployment-tax rate when it accrued eight quarters of reporting no employees or payroll by January 1, 2014. The statutory phrase "beginning January 1, 2014" establishes a cutoff date for accruing the required quarters, rather than a deadline for switching to client-level reporting. Because Great Oaks satisfied the eight-quarter requirement before that date, the Court reversed and remanded for assessment of the new-employer rate.