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ARTICLE · 18 JANUARY 2007

SST Governing Board Adopts Sourcing Rules, Repeals Multiple Points of Use Provision

Sutherland Asbill & Brennan LLP
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Recently, the Streamlined Sales Tax Governing Board adopted significant guidance concerning the sourcing of sales of software and computer-related services. Because there is scant state guidance associated with sourcing these transactions, the Governing Board’s actions provide meaningful simplification to multi-state taxpayers.

United StatesTax
Jeffrey Friedman
Jeffrey Friedman
Kendall Houghton
Kendall Houghton

Originally published December 15, 2006

Recently, the Streamlined Sales Tax Governing Board adopted significant guidance concerning the sourcing of sales of software and computer-related services. Because there is scant state guidance associated with sourcing these transactions, the Governing Board’s actions provide meaningful simplification to multi-state taxpayers. As part of the adoption of these sourcing rules, the Governing Board repealed the Multiple Points of Use provisions of the Streamlined Sales and Use Tax Agreement.

A copy of the sourcing rules is included at the end of this Legal Alert.

Background

General Sourcing Rules

The Streamlined Sales and Use Tax Agreement (the "Agreement") is a model sales and use tax law that has been adopted, in whole or in part, by approximately 20 states. Sections 309, 310, and 311 of the Agreement contain general sourcing rules. These rules are important because they control which jurisdiction is entitled to impose tax on a

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