The designation of a non-listed business or a payroll customer as an exempt person must be renewed biennially, beginning on March 15 of the second calendar year following the year in which the first designation of such customer as an exempt person is made, and every other March 15 thereafter...
The initial designation was filed on a date in 2006. The second calendar year following 2006 is 2008. The renewal, therefore, is due by 3/15/2008.
You reach the same renewal date conclusion for any initial filing date in calendar year 2006, from January 1 through December 31.
The regulation is not saying "by the last March 15 that is less than 2 years from the designation date."
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8