Welcome to the January 2026 edition of The BR State + Local Tax Spotlight. We know the importance of remaining up-to-date on State + Local Tax developments, which appear often and across numerous jurisdictions. Staying informed on significant developments and decisions helps tax departments function more efficiently, along with improving strategy as well as planning. That is where The BR State + Local Tax Spotlight can help. In each edition, we will highlight important State + Local Tax developments that could impact your business. In this issue, we will be covering:
- Words Matter: Use Tax Exemption Wins in Washington State!
- Ohio’s Permanent Escheatment Law May Proceed (For Now)
- Ohio BTA Rejects Commissioner’s Sourcing Method
- Washington Court Denies B&O Tax Refund to IT Company in Apportionment Dispute
Update from previous edition. In the October 2023 edition of The BR State + Local Spotlight, Craig B. Fields authored an article titled “Receipts from Products Delivered to Ohio Distribution Center for Subsequent Shipment Outside the State Are Not Sourced to Ohio” in which he discussed an Ohio Board of Tax Appeals (“Board”) decision. On December 24, 2025, the Ohio Supreme Court reversed the Board's decision, finding that the taxpayer’s sales were “properly situsable to Ohio” when shipped temporarily to purchasers with distribution centers in the state.
Joshua M. Sivin and Melanie L. Lee
ARTICLES
Words Matter: Use Tax Exemption Wins in Washington State!
By Mitchell A. Newmark
“Ease of administration cannot justify reading limitations into a statute that the legislature did not adopt.” Read More >>
Ohio’s Permanent Escheatment Law May Proceed (For Now)
By Eugene J. Gibilaro
While state unclaimed property or escheatment laws, at least in theory, exist to help reunite people with their lost property, states are increasingly coming to view unclaimed property as just another revenue source. Read More >>
Ohio BTA Rejects Commissioner’s Sourcing Method
By Melanie L. Lee
It is a foundational principle of statutory interpretation that statutes be read to give effect to their plain meaning. Read More >>
Washington Court Denies B&O Tax Refund to IT Company in Apportionment Dispute
By Stephanie N. Terinoni
In Valente Solutions LLC v. Department of Revenue, the Washington Court of Appeals addressed whether an information technology consulting firm was entitled to a refund of Washington business and occupation taxes for “localization services” provided to Microsoft. Read More >>
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