transaction tax update q4

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Transaction Tax Update

Transaction Tax Update November 2015

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Agenda

National Developments

– Internet Tax Freedom Act

– Marketplace Fairness Act

– Mobile Workforce State Income Tax Simplification Act

State Developments

– Nexus

– Miscellaneous

– Sales Tax Holiday Overview

Industry-Specific Developments

– Software/Cloud Computing

– Manufacturing

– Online Travel Companies

– Looking Forward: Emerging Industries

Q&A


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National Development: Internet Tax Freedom Act

Brief History

– Part of Public Law 105-277

– Original version of the bill was drafted by Representative Christopher Cox (R-CA) and Senator Ron Wyden (D-OR) in 1997

– Ultimately introduced by Representative Frank R. Wolf (R-VA)

– Signed into law by President Clinton on October 21, 1998


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National Development: Internet Tax Freedom Act Purpose?

– Keep the Internet free from taxes

How?

– Imposes a moratorium on the state and local taxation of Internet access and on multiple and discriminatory taxes on electronic commerce

Moratorium?

– Moratoriums, unlike exemptions, are imposed for a limited period of time

– To keep the moratorium in place, Congress must extend it

– Since its passage in 1998, the moratorium has been extended three times: 2001

2004

2007

2014


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National Development: Internet Tax Freedom Act

Recent Activity

– On September 18, 2014, President Obama signed House Joint Resolution 124, which includes provisions extending the Internet Tax Freedom Act through December 11

– On December 10, 2014, Congress passed an omnibus spending bill which included a provision to extend the moratorium for one year

– On September 30, 2015, Congress passed and the President signed a spending bill which includes a provision to extend the Internet Tax Freedom Act through December 11, 2015 Now Congress, once again, has the opportunity to either extend

the moratorium before it expires in December or make it final once and for all. We’ll have to wait and see.


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National Development: Marketplace Fairness

Historical Perspective

– Supreme Court held that only businesses with nexus via physical presence in a state can be required to collect sales tax for that state. The rationale behind this opinion was that it would be too burdensome for a remote business to collect tax for another state in which it has no physical presence

– Why Marketplace Fairness? Even playing field between online and brick-and-mortar retailers

Reduce burden on retailers

Make compliance easier


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National Development: Marketplace Fairness Act

Activity

– May 2013: Senate votes 69-27 to approve the Marketplace Fairness Act, but Act stalls in the House

– September 2013: Seven Basic Principles on Remote Sales Tax released by House Judiciary Committee

1. Tax Relief – Using the Internet should not create new or discriminatory taxes not faced in the offline world. Nor should any fresh precedent be created for other areas of interstate taxation by states.

2. Tech Neutrality – Brick-and-Mortar, Exclusive Online, and Brick-and-Click businesses should all be on equal footing. The sales tax compliance should not be less, but neither should it be greater.

3. Privacy Rights – Sensitive customer data must be protected.


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Activity

– (Seven Principles Continued)

4. No Regulation Without Representation – Those who bear state taxation, regulation, and compliance burdens should have direct recourse to protest unfair, unwise, or discriminatory rates and enforcement.

5. Simplicity – Governments should not stifle businesses by shifting onerous compliance requirements onto them; laws should be so simple and compliance so inexpensive and reliable as to render a small business exemption unnecessary.

6. Tax Competition – Governments should be encouraged to compete with one another to keep tax rates low, and American businesses should not be disadvantaged vis-a-vis their foreign competitors.

7. States' Rights – States should be sovereign within their physical boundaries. In addition, the federal government should not mandate that states impose any sales tax compliance burdens.


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Activity

– July 15, 2014: The Marketplace and Internet Tax Fairness Act (MITFA) was introduced in the Senate but gained no traction Key features

» Includes the Marketplace Fairness Act as passed by the Senate in 2013 with a few minor technical corrections

» Provides a ten-year extension of the Internet Tax Freedom Act (ITFA)

– January 2015: House Judiciary Chair Goodlatte released discussion draft of the Online Sales Simplification Act Unlike the Marketplace Fairness Act, this act adopts an origin-

based tax collection model and provides for a commission that oversees a distribution agreement addressing how tax is collected and distributed among the states

» Discussion draft excludes commission based click-through nexus from the definition of physical presence


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Recent Activity

– There has been little to no new activity since the bill was introduced into the Senate back in March. In March, it was read twice and referred to the Committee on Finance. March 10, 2015, Marketplace Fairness Act of 2015 (S. 698),

introduced in the U.S. Senate.

Would allow states meeting certain criteria to require out-of-state sellers to collect state and local sales and use taxes on sales made to customers in the state.

» Sellers meeting a “small seller exception” would be excluded.

Legislation is similar to the federal Marketplace Fairness Act of 2013 (S. 743) which was passed by the U.S. Senate on May 6, 2013.


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Workforce Sate Income Tax Simplification Act of 2015

H.R. 2315

– Would establish national rules that limit the authority of states to tax certain income of employees for duties performed in other states.

– Bill states an employee is not subject to income tax in a nonresident state unless they have worked at least 30 days in that state. Approved by the House Judiciary Committee on June 17, 2015

– Senate introduced a companion bill, S. 386, on February 5, 2015, and it has been referred to the Senate Finance Committee.


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State Developments: Nexus

Michigan – Enacted

– Michigan Revenue Administrative Bulletin 2015-22 (Nov. 3, 2015)

– Legislature passed Senate Bills 658 and 659

– Click-through nexus provision became effective October 1st

– Creates a presumption that a seller is engaged in business, if they or an affiliate engages in any of the following activities: Selling a similar line of products under the same or similar business

name;

Using the same or substantially similar trademarks, service marks, or trade names;

Delivering, installing, assembling, or performing maintenance or repair services for the seller’s in-state customers;

Allowing returns;

Having shared management, business systems, business practices, or employees.


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(Michigan Cont.)

– Also, creates a rebuttable presumption that a person is “engaged in business” in Michigan, if they enter into an agreement with an out-of-state seller whereby they receive compensation for referring potential customers by website link, oral presentations, etc., provided the seller: Earns at least $10,000 in sales through such agreements, and

Has at least $50,000 in Michigan sales by any means in the prior 12 months


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Tennessee - Enacted

– Effective July 1, 2015 Creates rebuttable presumption that out-of-state and online

retailers have nexus, if the seller enters into an agreement with a Tennessee resident to refer potential customers via a website link on the Tennessee resident’s website

» Online retailer’s cumulative gross receipts from traffic routed to the their website must exceed $10,000 in the preceding calendar year

» Presumption may be rebutted by “clear and convincing evidence” that the resident in agreement with the online retailer did not engage in any activities that would substantially contribute to the online retailer’s ability to establish and maintain a market


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Washington – B&O Nexus

– The activities of a nonresident independent sales representative established nexus for purposes of B&O tax for a non-resident retailer. The independent sales representative performed the following activities: Solicit Sales;

Drove a truck within a state bearing the retailer’s logo;

Delivered goods within the state.

Washington Department of Revenue Determination No. 14-0417, September 30, 2015.


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State Developments: Nexus Vermont

– Click-through nexus provision was passed in 2011 but was not set to take effect until similar nexus provisions were adopted by one-third of states imposing a sales and use tax

– The Attorney General must make the determination of whether the one-third trigger has been met No such opinion by the Attorney General has been provided

Something to keep an eye on in light of all the recent nexus activity

– UPDATE: The Department of Taxes issued a statement explaining its timeline for implementing click-through nexus Department will provide notice before beginning enforcement of

the law

Department will provide at least 30 days notice once the Attorney General issues the determination

» Statement of Vermont Department of Taxes on Vermont Click Through Nexus Law, Vermont Department of Taxes, August 2015


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Nevada – Effective July 1, 2015

– Creates a presumption that nexus exists for a remote seller if the remote seller is (1) part of a controlled group of business entities that has a component member who has physical presence in the state and (2) the component member engages in any of the following activities: Sells a similar line of products or services as the retailer and does so

under a business name that is the same or similar to that of the retailer;

Maintains an office, distribution facility, warehouse or storage place, or similar place of business in the state to facilitate delivery of tangible personal property sold by the retailer to the retailer’s customers;

Uses trademarks, service marks, or trade names in the state that are the same or substantially similar to those used by the retailer;

Delivers, installs, assembles, or performs maintenance services for the retailer’s customers within the state;


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Activities cont. Facilitates the retailer’s delivery of tangible personal property to

customers in the state by allowing the retailer’s customers to pick up tangible personal property sold by the retailer at an office, distribution facility, warehouse, storage place or similar place of business maintained by the component member in the state; or

Conducts any other activities in the state that are significantly associated with the retailer’s ability to establish and maintain a market in the state for the retailer’s products or services.

– Presumption may be rebutted by providing proof satisfactory to the Department that during the calendar year in question, the activities of the component member are not significantly associated with the retailer’s ability to establish or maintain a market in Nevada.


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State Developments: Nexus Alabama: Effective January 1, 2016

– Issued new rule that states out-of-state retailers who do not have physical presence in Alabama will be required to register for a license with the department and collect and remit sales and use tax when: The seller’s retail sales of tangible personal property sold into the

state exceed $250,000 per year based on the prior calendar year’s sales; and

The seller conducts one or more of the following activities set out in Ala. Code §40-23-68, which includes, but is not limited to:

» making delivery of retail sales of property within Alabama by means of a vehicle owned by the selling entity;

» soliciting and receiving orders for the sale of tangible personal property or taxable services by a representative, agent, salesman, canvasser, solicitor, or installer within the state;

Ala. Admin. r 810-6-2-.90.03


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State Developments: Nexus New Jersey (Technical Bulletin TB-79, July 30, 2015)

– The New Jersey Department of Revenue released Technical Bulletin providing guidelines for determining whether the activities of a person or business create Sales and Use Tax Nexus. Traditional nexus creating activities include, but are not limited to:

» Selling, leasing, or renting tangible personal property or specified digital products or services;

» Selling, storing, delivering, or transporting energy to users or customers;

» Parking, storing, or garaging motor vehicles.

Click-through nexus is established if:

» The seller enters into an agreement with a New Jersey independent contractor or other representative for compensation in exchange for referring customers via a link on their website, or otherwise, to that out-of-State seller; and

» The seller has sales from these referrals to customers in New Jersey in excess of $10,000 for the prior four quarterly periods ending on the last day of March, June, September, and December.


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State Developments: Miscellaneous

Virtual Currency

– New Jersey The New Jersey Department of Taxation updated its guidance

regarding the treatment of virtual currency.

» Convertible virtual currency is treated as intangible property; therefore, the use of such currency in a transaction is not subject to tax.

» Sales and Use tax does apply when a person transfers virtual currency for taxable goods or services.

» TAM-2015-1(R), July 28, 2015.


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Virtual Currency

– Michigan Taxpayers are required to remit sales and use tax based on the

dollar value of the consideration exchanged for the property.

If the consideration given in exchange for the property is not USD, the taxpayer must convert the value of the consideration to USD as of the date and at the time of the transaction;

» When the consideration is given in the format of virtual currency, the taxpayer accepting virtual currency must also maintain documentation demonstrating the value of the virtual currency on the day and at the exact time of the transaction.

» Treasury Update Volume 1, Issue 1 (November 2015).


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State Developments: State Amnesty Missouri

– Time Period: September 1, 2015 – November 30, 2015 Waives penalties and interest if outstanding tax liabilities are paid

by November 30, 2015.

Qualifying taxes include : Income Tax, Consumer’s Use Tax, Corporation Franchise Tax, Employer Withholding Tax, Sales Tax and Vendor’s Use Tax.

Alabama

– Alabama Tax Delinquency Amnesty Act of 2016

– Dates TBA Will take place in 2016, but before August 31, 2016 and will apply

to all taxes administered by the department except for motor fuel taxes.

» Taxes due prior to January 1, 2015; or

» Taxes for taxable periods beginning before January 1, 2015.


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State Developments: State Amnesty

Louisiana

– November 13, 2015 – December 15, 2015

– Installment 3 of 3

– The following taxes and tax periods are eligible: Taxes due prior to January 1, 2015, for which the Department of

Revenue has issued an individual or a business proposed assessment, notice of assessment, bill, notice, or demand for payment not later than May 31, 2015; or

Taxes for taxable periods that began before January 1, 2015; or

Taxes for which the taxpayer and the Department of Revenue have entered into an agreement to interrupt the running of prescription pursuant to La. R.S. 47:1580 and said agreement suspends the running of prescription until December 31, 2015.


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Industry-Specific Developments: Software

California

– Lucent Technologies, Inc. v. State Board of Equalization

Decision issued October 8, 2015

California Court of Appeals affirmed the state’s sales tax exclusion applicable to technology transfer agreements and affirmed more than $2.5 million in attorney’s fees to the taxpayer due to the Board of Equalization’s failure to pay “a refund to which it was undisputedly entitled under controlling law”

» Background: Like Nortel, the Lucent case involved a manufacturer’s sale of tangible personal property (TPP) to a communications company and its transfer to the company of a right to use software needed to operate the TPP. The BOE maintained that the software was taxable. The taxpayer, citing the state’s TTA statute and the decision in Nortel, maintained that the software was exempt.

» BOE has the right to appeal the decision to the California Supreme Court.


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Utah

– Company’s purchase of software interfaces is not subject to sales and use tax. Diagnostic testing company developed a software suite of

connectivity solutions to assent in receiving timely results, share clinical information and prescribe drugs by means of an interface that allows multiple systems to exchange data.

The company’s purchase of the interface was found to be exempt custom software because the interface was designed and developed to the specifications of the personal use of the purchaser.

» Utah Private letter Ruling 15-004 (September 28, 2015)


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Kansas

– Fact pattern the same as Utah. Likely same Taxpayer.

– Taxpayer’s purchase on an interface system which allows them to access medical records and test results stored on a remote computer system was nontaxable information or database access services. Kansas does not tax an “information” service or “database access

service” that consists of a collection of records or data that is stored in a remote computer system and contains software that allows the purchaser of the service to access the system electronically to answer queries or extract desired information.

» Kansas Private Letter Ruling P-2015-003, September 28, 2015


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Utah

– Use of online database held taxable. Taxpayer appealed an audit assessment, finding that their

purchase of SaaS and online database access was subject to sales and use tax.

Formal Hearing took place on October 28, 2015, and the Tax Commission upheld the audit finding.

The Utah Tax Commission applied the essence of the transaction test and determined that while the Taxpayer’s purchase of software access (SaaS) and online database access included nontaxable services in addition to the taxable use of prewritten software, the primary object or essence of the transaction was the use of the taxable software.

» Utah State Tax Commission Decision Appeal No. 10-2086 (October 14, 2015).


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Pennsylvania

– Taxpayer’s provision of services and infrastructure to an Internet service provider (ISP) was not subject to tax. Taxpayer sells various services including the provision of

infrastructure to Internet service providers who choose to outsource the creation and management of the infrastructure required for remote access to their Internet network to work.

In a Nutshell: Internet service providers sell Internet access to their end users and outsource the creating and management of physical infrastructure to the Taxpayer.

Court held the Taxpayer’s service to be exempt as Internet access.

» Level 3 Communications, LLC v. Commonwealth of Pennsylvania, October 15, 2015.


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Industry-Specific Developments: Software Missouri

– Taxpayer is a general contractor and construction management company that maintains a professional engineering license and uses “design build” computer software to perform engineering services.

– Mo. Rev. Stat. §144.615(3) provides an exemption from sales and use tax for computers, computer software, and computer security systems purchased for use by architectural or engineering firms headquartered in the state. To qualify for the exemption, an engineering firm must have four

separately integrated facilities.

» Separate buildings within a single complex at one location are not considered separately integrated facilities for purposes of the exemption.

– Taxpayer was found to not have the requisite integrated facilities and was therefore liable for tax. Missouri Letter Ruling No. LR 7600 (July 10, 2015).


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Industry-Specific Developments: Software New York TSB-A-15(34)S (August 17, 2015)

– Computer Server Co-locating services not subject to tax. Petitioner operates a facility in NY, where it provides secure and

temperature controlled storage for computer servers.

Petitioner has no interaction with the computer applications that run on the servers it stores.

Separately stated charges for storage space were found to be the exempt lease of real property based on the following factors:

» Customers are permitted to supply their own racks, equipment and cabinets

» Customer and its employees have 24-hour access to stored equipment

Petitioner’s charges to its customers for power were also exempt because they are part of the overall exempt lease of real property. However, if a separately stated charge based on an accurate measurement of the customer’s consumption of electricity is provided, that charge would be subject to tax.


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Industry-Specific Developments: Software New York TSB-A-15(36)S (September 18, 2015)

– Petitioner sells a hosted service that integrates with its customer’s systems to collect data that helps customers analyze, manage and communicate the cost, quality, and value of information technology. The Department concluded that the Petitioner’s line item IT billing

product was an information service. However, the exclusion for information services applied because the information provided was personal and individual in nature, was obtained exclusively from that specific customer and not from a common source, and it was not made available or furnished to others.

» As a result, the separately itemized charge for line item IT billing was not subject to tax.

» However, if a lump sum is charged for the line item IT billing services and the taxable sale of software, the entire charge will be subject to tax.


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Industry-Specific Developments: Software Vermont

– The Department of Taxes issued an update on cloud computing Vermont Fact Sheet No. FS-1084 (August 2015)

» Charges for computer software accessed solely on a cloud platform do not fall within the definition of tangible personal property and are therefore not subject to Vermont Sales and Use tax.


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Michigan

– Auto Owners Insurance Company v. Department of Treasury, Michigan Court of Appeals, (October 27, 2015) Michigan Treasury Department conducted a use-tax audit and

determined a use tax deficiency existed and issued a bill for taxes due.

Auto Owners paid the tax under protest and filed a complaint, seeking a refund tax and interest it paid.

The Court of Claims held in Auto Owners favor finding that the transactions were not subject to use tax because the software was never “delivered by any means” and ordered the Department to issue a refund.

The Department appealed and the Appellate Court, applying the incident to the service test, found that the transactions were not taxable because any tangible personal property was incidental to the exempt service provided.


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Chicago

– This past summer, the City of Chicago Department of Finance ruled that fees to stream television and movies as well as the electronic delivery of music and games are subject to the Amusement Tax, if delivered to customers in the city. Ruling essentially applies the nonpossessory computer lease tax

onto content delivered through a cloud-based environment.

» City of Chicago Amusement Tax Ruling #5 (June 9, 2015).


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Industry-Specific Developments: Manufacturing New Jersey

– J&J Snack Food Sales Corp., v. Director, Division of Taxation

J & J Snack Foods (“J&J”) manufactures pretzels and developed a pretzel warmer that it loans to customers who purchase large volumes of pretzels.

J&J was determined to owe use tax on the parts it purchased and sent to the NJ recipients of loaner pretzel warmers.

The current audit determined use tax applied to the parts. However, an earlier1992 audit determined that the replacement parts were not subject to tax.

» Among other things, J&J argued that the Division should be prohibited from assessing tax on the parts because such a conclusion contradicted the 1992 audit.

» The court ultimately upheld the audit assessment concluding:

» The 1992 determination was an erroneous application of the law; and

» J&J did not prove detrimental reliance or extreme circumstances that would overcome the public’s interest in tax assessments or require equitable estoppel.


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Industry-Specific Developments: Manufacturing Indiana

– Taxpayer denied exemption on the purchase of beer kegs.

– Taxpayer was a beer manufacturer who used kegs to store, transport, and serve beer. The taxpayer charged customers a deposit for the kegs, and this

led to the Department determining the kegs were subject to use tax as returnable containers which contain a finished product sold for consumption.

Taxpayer argued that the kegs should not be considered returnable because customers are not required to return them.

The Indiana Tax Court upheld the assessment citing a prior court finding that a container need not be returned to the party it was immediately acquired from in order to be considered “returned” and furthermore, the fact that the Taxpayer routinely received the kegs back was evidence that they were returnable containers.

Indiana Letter of Finding No. 04-20140089 (July 29, 2015).

» See Brambles Industries, Inc., v. Indiana Dept. of State Revenue, 892 N.E.2d 1287, 1290


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Industry-Specific Developments: Travel

New York

– Hotel operator was not allowed a credit for New York sales tax it paid on the purchase of continental breakfasts provided to guests. The continental breakfast was furnished as part of the hotel’s

overall service.

An exclusion from sales tax is provided for purchases of tangible personal property used in performing certain services. However, hotel services are not enumerated as one of the services to be excluded.

Therefore, the Division concluded that the hotel operator was not entitled to resale treatment of its purchase of continental breakfasts.

» Washington Square Hotel LLC, New York Division of Tax Appeals, Administrative Law Judge Unit, DTA Nos. 825405, 825505, and 825821, September 10, 2015.


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Oklahoma

– The Oklahoma tax commission determined a taxpayer’s rental of equipment that it intended to re-rent was exempt from sales tax as a resale transaction. Oklahoma Letter Ruling 15-004, September 25, 2015

Alabama

– A scaffold rental companies' labor charge for erecting, maintaining and dismantling were not subject to the rental tax. General rule: if the lessor also performs a separate service that is apart

from and not incidental to the leasing of the property, the fee for that service is not derived from the lease, and thus is not subject to lease tax.”

» The above applies regardless of whether the separate labor services are included in the rental agreement or in a separate contract.

» BROCK SERVICES, LLC 1670 E. CARDINAL DRIVE BEAUMONT, TX 77705-6623, Taxpayer, v. STATE OF ALABAMA DEPARTMENT OF REVENUE.


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Kentucky

– Streaming services not subject to tax. NETFLIX, INC. APPELLANT V. FINANCE AND ADMINISTRATION

CABINET DEPARTMENT OF REVENUE APPELLEE ORDER NO. K-24900

New York

– Petitioner’s sale of unlimited facility use or participation based memberships are exempt from state sales and use tax, but subject to local sales and use tax because the Petitioner’s facilities qualify as weight control salons, health salons or gymnasiums. TSB-A-15(35)S


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State Developments: Miscellaneous Ohio

– The irrigation system installed in a newly constructed golf course was found to be a taxable business fixture In its analysis, the court focused on the difference between a

fixture and a business fixture:

» The definition of a “fixture” among other things specifies that it primarily benefits the realty and not the business.

» A “business fixture” primarily benefits the business conducted by the occupant on the premises and not the realty.”

The court noted:

» The removal of the irrigation system would cause injury to the land rather than permanent fabrication and construction to the property; and

» The record indicated that installation of the irrigation system was separate from construction of the golf course with the primary intent of benefiting the business.

» Hoffman Properties, L.P. v. Testa, 2015-Ohio-3931


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Industry-Specific Developments: Travel

Rhode Island

– Room Resellers conducting business with hotels in Rhode Island are now required to register with the Rhode Island Division of Taxation, pay an annual $10 permit fee, and charge and remit sales, use and hotel taxes. Room Reseller is defined as “any person, except a tour operator (as

defined in RI Gen. Laws Section 42-63.1-2), that has any right, permission, license, or other authority from or through a hotel, to reserve or arrange the transfer or occupancy of, accommodations the reservation or transfer of which is subject to this chapter, such that the occupant pays all or a portion of the rental and other fees to the Room Reseller or Reseller.”

» Rhode Island Notice 2015-14 (September 1, 2015)


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Looking Forward – Emerging Industries Technology is constantly changing, and tax laws are playing catch-up. Here are just some of the things we’re thinking about:

– Shared Service Economy Uber

Lyft

BlackJet (Uber for airplanes)

Swifto (Uber for dog walking)

– Online Travel Companies Air BNB

– Non-traditional Delivery Methods Drone Delivery

– Fantasy Sports Draft Kings

Fanduel

» Amusement service or gambling??


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Looking Forward – Emerging Industries Cloud Computing and Software - Data Centers

– As e-commerce and cloud-based software/services continue to grow, so does the need for dedicated equipment and even locations to manage these activities; many states offer tax exemptions, incentives and credits.

– The following states have a data center exemption in place:

Alabama

Arizona

Georgia

Iowa

Kentucky

Maine

Minnesota

Mississippi

Missouri

Nebraska

New York

North Dakota

Ohio

South Carolina

South Dakota

Tennessee

Texas

Virginia

Washington

Wyoming


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Contact Information Jeremiah T. Lynch

Principal and Practice Leader

National Tax

[email protected]

212.871.3901

Christopher Potter Director

National Tax

[email protected]

781.359.3800

Andrea Piersma Manager National Tax [email protected] 425.440.2333

mailto:[email protected]



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This document is presented by Ryan, LLC for general informational purposes only, and is not intended as specific or personalized recommendations or advice. The application and effect of certain laws can vary significantly based on specific facts, and professional advice of any nature should be sought

only from appropriate professional advisors. This document is not intended, and shall not be deemed, to constitute legal, accounting or other professional advice.

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