The Impact of Physical Presence Nexus on State Taxation: A Case Study of Citibank

• The focus on state tax nexus has been on economic nexus laws, but physical presence nexus still applies.
• The Washington Court of Appeals addressed whether Citibank had physical presence for B&O Tax purposes in Washington.
• Citibank generated revenue from credit card operations and had agreements with retailers in Washington.
• The Department of Revenue conducted an audit and assessed Citibank $6 million in B&O Tax.
• Citibank argued that it did not have nexus in the state.
• The Court relied on a Washington Supreme Court decision that stated physical presence can be satisfied by activities within the state.

Source: aprio.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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