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OSBA Sales & Use Tax Subcommittee Highlights Recent Cases – February 2025

I. NON-TAXABLE SERVICES - A. Personal / Professional Services: Checkfree Services Corp. v. Harris, Ohio BTA Case No. 2019-43 (October 10, 2024) on appeal before Ohio Supreme Court (Case No. 2024-1569). The BTA held that...more

Ohio Sales / Use Tax: Financial authorization services found to be nontaxable, although appeal remanded for further consideration...

The Ohio Board of Tax Appeals held that certain financial authorization services, Debit Authorization as described below, are not taxable automatic data processing processing (“ADP) or electronic information services (“EIS”)....more

Ohio Sales Tax Exemptions Businesses Should Know

Generally, in Ohio, sales of tangible property are taxable unless an exemption exists, whereas services are generally nontaxable unless specifically enumerated as taxable under the Ohio Revised Code. However, Ohio has many...more

Maximizing Ohio Sales and Use Tax Exemptions for Businesses

In Ohio, sales of tangible personal property are presumed taxable unless an exemption exists. On the other hand, services are presumed nontaxable unless specifically enumerated as taxable under Ohio’s Revised Code. Many of...more

Ohio CAT Tax Changes for 2024 and 2025.

Preparing for significant changes to Ohio commercial activity tax for 2024 – Majority of taxpayers will no longer be subject to CAT following increases in annual exclusions. Ohio’s Budget Bill (H.B. 33) significantly...more

OSBA Sales & Use Tax Subcommittee Highlights Recent Cases - September 2023

1. EXEMPTIONS - A. Equipment Used in Production of Crude Oil and Natural Gas: Stingray Pressure Pumping, LLC v. Harris, Slip Opinion No. 2023-Ohio-2598. Reversing the BTA, the Court determined five categories of...more

Ohio State Bar Association Taxation Committee - Sales/Use Tax Subcommittee Report - February 2023

I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more

OSBA Sales & Use Tax Subcommittee Highlights Recent Cases - January 2022 Update

The OSBA Sales/Use Tax Subcommittee Report discusses recent developments concerning the scope of taxable services, as well as the federal preemption of taxation on internet services which were previously taxable in Ohio....more

OSBA Sales & Use Tax Subcommittee Highlights Recent Cases - September 2021

The OSBA Sales/Use Tax Subcommittee Report discusses recent developments concerning the scope of taxable services, as well as the federal preemption of taxation on internet services which were previously taxable in Ohio....more

Ohio Sales / Use Tax: Who controls your trash? Critical contractual distinction determines tax exemption for waste haulers,...

The Ohio Supreme Court recently ruled that a waste-hauler was entitled to Ohio’s transportation-for-hire exemption from sales / use tax on trucks used to haul trash to customer-designated locations. In N.A.T. Transportation,...more

OSBA Sales & Use Tax Subcommittee Report Highlights Recent Cases - September 2020

I. EXEMPTIONS - Resale Exemption - Domokur Aviation Services, LLC v. McClain, Ohio BTA Case No. 2019-694 (September 15, 2020). Applying the Supreme Court’s decision in Pi in the Sky, LLC v. Testa, 155 Ohio State 113,...more

Marketplace facilitators making interstate sales collect Ohio sales tax based upon the consumer’s destination

Sourcing sales is critical to determine the appropriate jurisdiction and tax rate for Ohio sales tax collection purposes. Recently, the Ohio Department of Taxation revised Information Release ST 2009-03 to reflect that sales...more

Ohio sales / use tax: Statute expanding oil & gas exemption applies retroactively to purchases of hydraulic fracturing equipment

The Tenth District Ohio Court of Appeals recently applied a statutory amendment clarifying the oil & gas exemption for Ohio sales & use tax retroactively. Interestingly, while this appeal was pending at the Board of Tax...more

Ohio BTA departs from previous ruling and holds that installing internet cable lines are nontaxable real property improvements

The Ohio Board of Tax Appeals recently overturned precedent and held that the installation of standard internet cable lines constituted nontaxable real property improvements rather than taxable business fixtures. Nationwide...more

Paving the Way to Tax Refunds | Firm Wins Big for Ohio Heavy Highway Contractors

Buckingham Tax Attorneys Steve Dimengo and Rich Fry recently obtained a favorable ruling from the 9th District Court of Appeals for their client in Karvo Paving Co. v. Testa, 2019-Ohio-3974. This victory enables highway and...more

OSBA Sales & Use Tax Subcommittee Report Highlights Recent Cases - September 2019

The report highlights the recent changes to Ohio law requiring out-of-state sellers and marketplace facilitators to collect tax on sales into the state, as well as recent cases decided by the Ohio Board of Tax Appeals....more

Getting Counsel Involved Early can Save your Ohio Sales / Use Tax Refund

Recently, the Ohio Board of Tax Appeals (BTA) denied a taxpayer’s sales tax refund in part because it could not consider the taxpayer’s improperly submitted evidence. In Environmental Quality Management Inc. v. McClain, BTA...more

Ohio Sales / Use Tax: Ohio joins the wave by enacting Wayfair economic nexus standards and expanding collection obligations to...

Nexus for Ohio sales / use tax collection expands effective August 1, 2019 to include out-of-state sellers and marketplace facilitators that deliver at least $100,000 of sales or 200 transactions to Ohio. Ohio’s General...more

Multistate Sales Tax: States continue to roll out their own economic nexus laws in response to Wayfair

We are approaching one year since the U.S. Supreme Court overruled 50 years of precedent to eliminate the “physical presence” bright-line rule for substantial nexus in its South Dakota v. Wayfair decision. Most states have...more

Earth-shattering tax liability means doomsday for vendors: Don’t put your personal net worth at-risk

Vendors selling out of state but not collecting sales tax are on a path to suffering severe financial loss. The tax liability could be astronomical – enough to devastate a business – as high as 10% or more of total sales for...more

Practical Law - Sales and Use Tax for Remote Sellers: Ohio

A Q&A guide to remote sellers’ exposure to sales and use tax in Ohio after the US Supreme Court’s decision in South Dakota v. Wayfair, Inc. in 2018. This Q&A addresses issues including nexus for remote sellers, taxability...more

Ohio’s Municipal Net Profits Tax Reform Constitutional – Centralized filing provides significant administrative benefits to...

Ohio’s efforts to substantially simplify its municipal income tax regime – a much-needed reform – is permitted to move forward. Ohio instituted municipal income tax reform, which took effect with the 2018 tax year, permitted...more

OSBA Sales & Use Tax Subcommittee Report Highlights Recent Cases

This Report highlights recent cases interpreting the scope of the resale exemption, employment services, and building maintenance and janitorial services. In particular, the recent case concluding that employment services are...more

Ohio Supreme Court Rejects Taxes on Draft Beer Tap Maintenance and Cleaning

Ohio Supreme Court rejects taxes on draft beer tap maintenance and cleaning–limits scope of taxation on janitorial-type services....more

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