Category Archives: Ohio

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Where’s My Sales? – Sourcing Sales Receipts for Ohio CAT Purposes

The cornerstone of any taxing regime is the situsing of receipts.  The taxpaying public must have certainty regarding when its income is subject to tax in a jurisdiction.  Recent rulings from the Ohio Department of Taxation (the “Department”) regarding the situsing of receipts for the Ohio Commercial Activity Tax (“CAT”), however, inject ambiguity into what … Continue Reading

On Shaky Ground: Are Pass-Through Entity Withholding Statutes Constitutional?

Taxpayers routinely use pass-through entities (PTEs) such as limited partnerships, limited liability companies, or S corporations to conduct multistate business. Because most states conform to federal law, there is no entity-level tax on the PTE. Instead, states seek to tax the owners of the PTE on the income received – or passed-through – from the … Continue Reading
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