Recent Ohio Supreme Court decisions addressing the situsing of receipts under the Commercial Activity Tax (CAT) underscore both the limits of the “continuous delivery theory” and the evidentiary hurdles taxpayers face when seeking refunds for transactions involving Ohio distribution centers. Read together, VVF Intervest, L.L.C. v. Harris, Slip Op. No.…
The Supreme Court of Ohio has held the Ohio legislature did not violate the Due Process Clause of the U.S. Constitution by directing an Ohio citizen to pay taxes to the municipality where the employee’s principal place of work was located rather than to where the employee actually worked. During…
In a much-anticipated decision concerning the situsing of receipts from intangibles for Ohio commercial activity tax (CAT) purposes, the Ohio Supreme Court rejected the Ohio Department of Taxation’s attempt to situs NASCAR Holdings, Inc.’s broadcast revenue, media revenue, licensing fees, and sponsorship fees to Ohio. The court’s opinion in NASCAR Holdings,…