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New York ALJ rejects attempt to apply sourcing rules for “other business receipts” to online travel reservation services

An administrative law judge (ALJ) in the State of New York Division of Tax Appeals has determined that a taxpayer’s receipts for facilitation of online travel reservations were from providing a service and should be sourced based on where the service was performed. In issuing this determination, the ALJ rejected an attempt by the New York State Department of Taxation and Finance to source the receipts as “other business receipts” and source to where the receipts were earned. At this point, it is not known whether the Department is going to appeal this decision to the New York State Tax Tribunal.

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