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Washington DOR Responds to the LendingTree Decision: Benefit of the Service May Still Occur at the Customer’s Customer Location

by and 4 Mins Read

On July 21, the Washington Department of Revenue (“DOR”) issued its analysis of the Court of Appeals’ decision from March 30, 2020, in LendingTree, LLC v. Dep’t of Revenue, no. 80637-8-I (Wash. App. Ct. Mar. 30, 2020).  As set forth in the analysis, from the DOR’s perspective, the LendingTree court followed the existing Washington Business and Occupation tax (“B&O”) attribution rules and guidance and did not create a new interpretive legal framework.[1]  Although the DOR lost the case, and the court held that LendingTree’s receipts could not be sourced based where its customers’ customers were located, the DOR’s response suggests that they are factually distinguishing the case and will continue to attribute receipts to the customer’s customer location if that is where it determines the benefit of the services occurs.

Coronavirus Relief Bill Attempts to Address SALT Matters for Telecommuting Employees

by and 3 Mins Read

On Monday, July 27, the Senate Finance Committee released draft legislative provisions (“COVID-19 Bill”) regarding the next iteration of Coronavirus relief.  Somewhat surprisingly, the provisions include the Remote and Mobile Worker Relief Act of 2020, which was introduced earlier this year as S. 3995 by Sens. Sherrod Brown (D-OH) and Jon Thune (R-SD). S. 3995 appears to be based on S. 604, the Mobile Workforce State Income Tax Simplification Act (“Mobile Workforce Act”), which was…

State and Local Tax Responses to COVID-19: Corporate Income Tax and Sales and Use Tax Deadline Extensions

by , , , , , , , , , , , , , , , , , , and 1 Min Read

Numerous states have provided tax relief in response to the COVID-19 outbreak, often in the form of tax filing and payment deadline extensions.  At this time, 40 states and Washington, D.C. have provided a corporate income tax filing and/or payment deadline extension.  Some of these states have conformed to the July 15 federal corporate income tax extension date, while others have extended to an earlier or later date.  Some states have also extended income tax…

Washington State’s Nexus Blitz Against Riot Games

by 4 Mins Read

Riot Games, Inc. (“Riot”) is the developer and publisher of League of Legends (“LoL”), a popular multiplayer online battle arena game.[1]  In LoL, two teams of five players each battle to destroy each other’s Nexus, or base.  Players control characters that have various different attacks and abilities.  Each team also has minions that stream towards the other team’s base, and each team attempts to protect their base by attacking other characters and pushing their own minions forward and stopping the other team’s minions from advancing.  In 2018, Riot had a version of the game called Nexus Blitz.  Although Riot hasn’t brought back Nexus Blitz since 2018, it has had to deal with another nexus attack from Washington State.

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