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Sales and Use Taxes: Services (Portfolio 1310)

Product Code: TPOR44
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Sales and Use Taxes: Services provides readers with information and suggestions to help them conduct efficient transaction planning.  Written by Lawrence Fee, J.D., LL.M., Sharon Murphy, CPA, and Paul Mortenson, J.D., CPA, this Portfolio briefly traces the historical development of sales tax generally and taxation of services specifically, analyzing the approach taken by each state in extending the sales tax to encompass service transactions, and it examines evolving issues associated with sales taxation of services.  

The bulk of this Portfolio provides state-by-state analysis and reviews the legislation of each state as it relates to miscellaneous taxable services.  Although Sales and Use Taxes: Services does not cover contracting, information, computer software, and telecommunications services, it does address all other professional and personal services, repair and installation services, and utility services.  

Sales and Use Taxes: Services also addresses two significant areas of evolving issues. One is the judicial and administrative interpretations of transactions involving both sales of services and tangible property. These “mixed transactions” are analyzed using the “true object” test (i.e., whether the “true object” of the consumer is to obtain a tangible item or a service). Different bodies have explicitly referred to the analysis by name or have adopted the approach without explicit endorsement of the term. This Portfolio reviews, on a survey basis, state decisions interpreting the “true object” test. 

The other evolving issue addressed in this Portfolio is the use taxation of services benefiting a multistate consuming entity. The specific issue addressed is how such use can and should be taxed in a multistate environment. This analysis is conducted by reviewing two highly publicized efforts to legislate approaches to this issue. These logical but ultimately unsuccessful efforts were made by the states of Florida and Massachusetts.  

The included worksheets address the 1982 SIC listings with their respective 1997 NAICS codes, warranties and service agreements, and the taxability of landscaping services.  

Sales and Use Taxes: Services allows you to benefit from: 

  • Hundreds of hours of original research on specific tax planning topics from leading practitioners in this area.
  • Invaluable practice documents including tables, charts and lists.
  • Plain-English guidance from world-class experts.
  • Real-world and in-depth analysis that lets you explore various options.
  • Time-saving access to relevant sections of tax laws, regulations, court cases, IRS documents and more.
  • Alternative approaches to both common and unique tax scenarios.

This Portfolio is part of the Premier State Tax Library, a comprehensive series, which covers major state tax transactions and issues with expert, in-depth analysis, and offers commentary on a wide range of multi-state and state-specific taxation topics, including Sales and Use, Corporate Income, Individual Income, Property, Gross Receipts, Limitations on States' Authorities to Tax, Credits and Incentives, Electronic Commerce, Mergers and Acquisitions, Procedure and Administration, Special Industries, and more.

 

Detailed Analysis

1310.01. HISTORICAL DEVELOPMENT

A. Introduction

B. Sales Taxes Generally

C. Taxation of Services

D. Statutory Analysis

E. Observations and Assumptions

1310.02. CURRENT AND EVOLVING ISSUES

A. The True Object Test

1. Variants of the True Object Test

2. The True Object Test in Various States

a. Alabama

b. California

c. Colorado

d. Connecticut

e. District of Columbia

f. Florida

g. Georgia

h. Idaho

i. Illinois

j. Indiana

k. Kentucky

l. Maine

m. Maryland

n. Massachusetts

o. Michigan

p. Minnesota

q. Missouri

r. Nebraska

s. New Jersey

t. New York

u. North Carolina

v. Ohio

w. Oklahoma

x. Rhode Island

y. South Carolina

z. Tennessee

aa. Texas

bb. Virginia

cc. Washington

dd. West Virginia

ee. Wisconsin

B. The Florida And Massachusetts Experiments – Logic That Failed

1. Florida

2. Massachusetts

C. Use Taxation Of Services Under The Florida And Massachusetts Acts

1310.03. ALABAMA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.04. ALASKA

1310.05. ARIZONA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.06. ARKANSAS

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.07. CALIFORNIA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.08. COLORADO

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.09. CONNECTICUT

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.10. DELAWARE

1310.11. DISTRICT OF COLUMBIA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.12. FLORIDA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.13. GEORGIA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.14. HAWAII

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.15. IDAHO

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.16. ILLINOIS

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.17. INDIANA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.18. IOWA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.19. KANSAS

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.20. KENTUCKY

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.21. LOUISIANA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.22. MAINE

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.23. MARYLAND

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.24. MASSACHUSETTS

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.25. MICHIGAN

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.26. MINNESOTA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.27. MISSISSIPPI

Introductory Material

A. Miscellaneous Taxable Services

B. Professional Services

C. Repair and Installation Services

D. Utilities

1310.28. MISSOURI

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.29. MONTANA

1310.30. NEBRASKA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.31. NEVADA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.32. NEW HAMPSHIRE

1310.33. NEW JERSEY

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.34. NEW MEXICO

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.35. NEW YORK

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.36. NORTH CAROLINA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.37. NORTH DAKOTA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.38. OHIO

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.39. OKLAHOMA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.40. OREGON

1310.41. PENNSYLVANIA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.42. RHODE ISLAND

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.43. SOUTH CAROLINA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.44. SOUTH DAKOTA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.45. TENNESSEE

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.46. TEXAS

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.47. UTAH

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.48. VERMONT

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D Utilities

1310.49. VIRGINIA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.50. WASHINGTON

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.51. WEST VIRGINIA

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.52. WISCONSIN

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

1310.53. WYOMING

Introductory Material

A. Miscellaneous Taxable Services

B. Professional and Personal Services

C. Repair and Installation Services

D. Utilities

Working Papers

Item Description Sheet

Worksheet 1 1987 SIC Matched to 1997 NAICS Services Industries

Worksheet 2 Warranties and Maintenance Agreements

Worksheet 3 Taxability of Landscaping Services

Bibliography

BIBLIOGRAPHY

Lawrence Fee
Lawrence H. Fee, B.A., University of Illinois at Chicago (1976); J.D., John Marshall Law School (1980); LL.M., John Marshall Law School (1984); Editorial Advisory Board, Journal of Property Tax Management; Member: Chicago Bar Association, State and Local Tax Committee, Federal Communications Bar Association. 
Paul Mortenson
Paul D. Mortenson, B.S., Merrimack College (1989); J.D., Suffolk University Law School (1992); Certified Public Accountant (Illinois, 1993); Member: Chicago Bar Association, State and Local Tax Committee, American Bar Association. 
Sharon Murphy
Sharon A. Murphy, B.A., Mercyhurst College (1985); M.S.T., Robert Morris College (1992); Member: American Institute of Certified Public Accountants, Pennsylvania Institute of Certified Public Accountants.