- The Ohio Supreme Court ruled that a contract manufacturer’s sales must be sitused to Ohio, denying the company a Commercial Activity Tax (CAT) refund.
- The Court interpreted the law to mean that situsing is determined by where the purchaser receives the goods, which in this case was Columbus, Ohio.
- The company’s alternative argument and all constitutional challenges (Due Process, Commerce Clause, Equal Protection) were rejected.
- The Court found that the company had substantial nexus with Ohio and that the CAT was fairly related to state-provided benefits.
- Taxpayers dealing with Qualified Distribution Centers are not similarly situated to others, justifying different legislative treatment.
Source: salestaxinstitute.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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