The Alabama Taxpayers’ Newsletter Published periodically by JEFF PATTERSON LLC — All rights reserved ™ Issue 7-2015 ADOR DIRECTS OUT-OF-STATE SELLERS TO COLLECT ALABAMA USE TAX—IS THIS THE NEXT QUILL CASE? The law firm of JEFF PATTERSON LLC was founded to represent taxpayers. Its clients include in-state and out-of-state business entities — both large and small — and individuals. Because JEFF PATTERSON LLC highly values confidentiality, the firm does not disclose the identity of its clients. Prior to founding the firm, Jeff Patterson practiced law inside the Alabama Department of Revenue for more than 13 years. The firm represents clients before state and local tax agencies in Alabama, and before the IRS, and has represented clients before tax agencies in other states and before the United States Supreme Court. The following is a partial list of the firm’s areas of representation: sales and use taxes income tax business privilege tax trust fund recovery penalty local taxes federal income/excise taxes tax incentives regulatory matters audits (incl. third party) tax litigation property tax tax-exempt recognition collection matters unclaimed property. Friday, the Alabama Department of Revenue officially proposed a rule that would require out-of-state (remote) sellers who have no physical presence in this state to collect use tax from their Alabama customers and to remit that tax to the ADOR. (810-6-2-.90.03) The rule would apply to the purchase of items over the internet, and by catalog and phone. Some well-known examples of remote sellers are Amazon.com, Overstock.com, and LL Bean. Although the rule was announced Friday in the Alabama Administrative Monthly, the text of the rule has not yet been released. Currently, remote sellers are not legally required to collect Alabama sales or use tax, because of the 1992 decision by the United States Supreme Court in Quill Corp. v. North Dakota. (Nevertheless, some remote sellers do so voluntarily.) In Quill, North Dakota argued that the company should have collected and remitted use tax on catalogue goods that were purchased by North Dakotans for use within the state. However, because Quill had no physical presence in North Dakota, the court held that the tax violated the Interstate Commerce Clause. Although the case involved use tax, the court applied its reasoning to sales tax, as well. Thus, today, most remote sellers who sell to Alabama customers do not collect sales or use tax, which appears to “save” customers around 10% per purchase. (Of course, if no sales tax is paid, the use of the property in Alabama creates a use-tax liability for the Alabama customers, but most do not pay the tax.) It is clear that the Quill holding trumps the ADOR’s proposed rule. Therefore, it appears that the ADOR is attempting to set the stage for the Supreme Court to revisit the issue of state taxation of remote sales. Only time will tell if the court will be amenable. It is interesting to note, though, that 6 of the current justices were not members of the Quill court. And recently, current Justice Anthony Kennedy, who was a member of the Quill court, stated that “the legal system should find an appropriate case for this court to reexamine Quill …” (Direct Marketing Assn v. Brohl) The ADOR’s first challenge, however, is to adopt the rule once the public-hearing process has ended, and then hope that the rule is not suspended by the legislature’s Joint Committee on Administrative Regulation Review. As we know from recent events (i.e., the ADOR’s proposed rule on taxing digital transmissions), the committee has the authority to suspend an administrative rule. If the committee does so here, and if the legislature upholds the suspension in the 2016 regular session, Alabama’s version of the Quill case will not materialize. JEFF PATTERSON LLC The Alabama Taxpayers’ Newsletter ™ For more information, contact the firm. JEFF PATTERSON LLC Park Place Center Suite 204 8650 Minnie Brown Road Montgomery, AL 36117 334.215.4446 (office) 334.462.8438 (cell) www.jeffpattersonlaw.com email: jeffpatterson@jeffpattersonlaw.com Parting Shot: “This is too difficult for a mathematician. It takes a philosopher. ” Albert Einstein (on filing a tax return) The contents of The Alabama Taxpayers’ Newsletter ™ do not constitute the rendering of legal advice and cannot be construed as such; nor does this newsletter evidence the existence of an attorney-client relationship. The Alabama Taxpayers’ Newsletter ™ may not be reproduced in whole or in part without first obtaining the express written permission of JEFF PATTERSON LLC. Alabama State Bar Rule 7.2(e) requires the following statement: No representation is made that the quality of legal services to be performed is greater than the quality of legal services performed by other lawyers. 2