United States

Multiple points of use and the cloud

DIY isn’t just for home improvement


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The Streamlined Sales and Use Tax Agreement (SSUTA) multiple points of use (MPU) provisions were a novel and highly promising apportioned approach to sourcing sales of goods and services intended for concurrent use in multiple states.  If adopted generally, the SSUTA MPU provisions would have provided much-needed relief from multiple taxation in circumstances where more than one state could rightfully assert that it had first claim to taxing a transaction and deny credit for taxes paid to other states.  However, in the face of concerns by taxpayers and tax authorities alike, the provisions were repealed, leaving taxpayers with little guidance or protection against multiple taxation.

In this article, first published by Bloomberg BNA, RSM’s state and local tax professionals consider the application of sales and use tax to purchases of cloud-based digital goods and services that are intended for concurrent use in multiple states and evaluate the problems inherent in the current system absent some form of universal MPU relief. 

The article also provides taxpayers with examples of do-it-yourself approaches to reducing multiple-taxation risk in MPU transactions.

Read the article to understand how the sourcing of cloud-based digital goods and services became the problem it is today and several possible taxpayer-driven solutions that companies can implement while waiting for legislation to catch up with modern business practices.


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