98-013

Response January 30, 1998

 

 

 

REQUEST LETTER

 

MEETING: January 28, 1998

 

1. TAXATION:

 

a. XXXXX County's tax records indicate COMPANY A will be taxed at about $$$$$ annually or about $$$$$ for land and about $$$$$ for equipment and buildings. Is this correct? What is the formula? How frequent is the data base updated? What is the projected rate for 5-10 years?

 

b. Sales and Use Tax on Equipment: Utah provides limited tax credits for equipment purchased in Utah. How does this effect equipment that cannot be purchased or manufactured in Utah? Who determines if the equipment is taxable or non-taxable? What can be used as a guideline for equipment? When the company uses raw products, are the raw materials taxed when purchased outside of the state and shipped to Utah? How are the taxes determined, or are they taxed? An example, the company brings rice from STATE, hard wheat and brand from Canada soft grains from STATE, and other raw goods from indigenous areas of the United States and Canada. How are these products treated with respect to tax?

 

c. Inventory Tax: We understand Utah does not charge manufactured or finished goods tax. It this correct?

 

d. Corporate Tax: COMPANY A is a type "S" corporation. It is our understanding the franchise tax will apply to the company, an income tax will not Is this true?"

 

e. Can COMPANY A get a summary statement of interpretation concerning each of these tax questions and issues?

 

 

 

RESPONSE LETTER

 

 

January 12, 1998

 

 

 

NAME

ADDRESS

CITY STATE ZIP

 

Advisory Opinion: Taxation of Business Located in XXXXX County

 

Dear NAME:

 

This advisory opinion is a follow-up to our conversation on Thursday, January 29, 1998. Because we do not have specific information about the business at issue, this letter provides only general guidelines. If you or the business client need more specific tax guidance, please contact us again with more detailed information.

 

1. All real and personal property in Utah is to be assessed and taxed at its fair market value unless otherwise exempt. The county assessor will assess the real property each year. Its value may vary from year to year with fluctuations in the market.

 

The personal property will be assessed each year at market value. Market value is generally determined by reference to the Tax Commission’s depreciation schedules. These schedules are updated each year by the Tax Commission’s Property Tax Division. The current schedules are enclosed for your review. There is a property tax exemption for property held in inventory for resale.

 

The tax rates in XXXXX County vary from year to year and from area to area. The 1997 tax rates for unincorporated XXXXX County ranged from .008895 to .01. The tax rates for incorporated areas ran from .010260 to .011500.

 

2. Unless otherwise exempt, sales and use tax applies to sales, use or consumption of tangible personal property in this state, as well as to charges for various services. Because we do not have specific details about the types of sales or purchases that your client makes, we cannot give you specific advice as to the kinds of exemptions that may apply. However, from your general description, it appears that your client may be a manufacturer. On that basis, we offer the following guidelines.

a. Purchases or leases of manufacturing equipment by a qualified manufacturer are exempt from sales tax. To qualify, the company’s operations must constitute a new or expanding business and must be an establishment described in SIC Code 2000-3999 of the 1987 Standard Industrial Classification Manual. The machinery or equipment purchased must be used in the manufacturing process which produces tangible personal property, and must have an economic life of three or more years.

 

b. Replacement parts are eligible for exemption as follows:

 

1. For purchases between July 1, 1997 and June 30, 1998, 60% of the sale or lease is exempt.

2. For purchases after July 1, 1998, 100% of the sale or lease is exempt.

 

Replacement parts must also be used in the manufacturing process, must have an economic life of three or more years, and must be used to replace or adapt an existing machine to extend the normal estimated useful life of the machine. Routine repair and maintenance does not qualify for exemption.

 

c. Raw materials that are purchased and used primarily as an ingredient or component part of the finished product may be purchased tax free for resale. Materials purchased and consumed by the manufacturer in the manufacturing process are taxable to the manufacturer, even if they become an incidental part of the finished product.

 

d. Items purchased from out-of-state vendors and shipped into Utah are subject to use tax in the same manner that the sales tax applies to in-state purchases. Therefore, if your client purchases exempt manufacturing equipment and machinery from out-of-state, it is exempt from use tax under the guidelines expressed in 2.a. and 2.b. above. Raw materials purchased from outside of Utah are exempt from use tax under the guidelines expressed in 2.c.

 

e. Utah does not charge manufactured or finished goods tax.

 

3. S corporations are taxed for state purposes in the same manner as taxed for federal purposes. That is, if a corporation obtains a valid Sub Chapter "S" election from the IRS, it will be treated as a Utah Small Business Corporation for tax purposes in Utah.

 

a. For Utah resident shareholders, taxable income, expenses, losses and credits pass through to the shareholders as provided in Subtitle A, Chapter 1S, Part 2 of the Internal Revenue Code.

 

b. Nonresident shareholders are liable for that portion of the corporation’s Utah taxable income that is derived from Utah sources. However, the corporation shall make a 5.95 percent payment on behalf of any nonresident shareholders. The individual nonresident shareholder may then file a Utah nonresident return to claim a credit for the amount paid by the corporation on that shareholder’s behalf.

 

c. A nonresident individual shareholder who has no other Utah source income may forego the credit described in 3.b. above and elect not to file a Utah return. However, if the shareholder intends to claim the credit, it must use the Utah return to do so.

 

I hope this information is helpful. Again, if you need a more detailed response, we are happy to work with you further.

 

For the Commission,

Joe B. Pacheco,

Commissioner

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