TITLE 34.PUBLIC FINANCE

Part 1. COMPTROLLER OF PUBLIC ACCOUNTS

Chapter 3. TAX ADMINISTRATION

Subchapter A. GENERAL RULES

34 TAC §3.5

The Comptroller of Public Accounts proposes an amendment to §3.5, concerning waiver of penalty or interest. Subsection (b)(8) is added to state that if Revenue Accounting Division denies waiver request for penalty, the standard of review in a resulting contested proceeding will be based on the factors considered by Revenue Accounting Division in its denial. This change is necessary to eliminate the conflict that currently exists. The proposed amendment to subsection (c) makes conforming change consistent with new subsection (b)(8), and all other proposed amendments are made for clarity and reflect existing agency policies.

James LeBas, Chief Revenue Estimator, has determined that for the first five-year period the rule will be in effect, there will be no significant revenue impact on the state or units of local government.

Mr. LeBas also has determined that for each year of the first five years the rule is in effect, the public benefit anticipated as a result of enforcing the rule will be in providing additional information regarding tax responsibilities. This rule is adopted under Tax Code, Title 2, and does not require a statement of fiscal implications for small businesses. There is no significant anticipated economic cost to individuals who are required to comply with the proposed rule.

Comments on the proposal may be submitted to Eleanor Kim, General Counsel Division, P.O. Box 13528, Austin, Texas 78711.

This amendment is proposed under Tax Code, §111.002, which provides the comptroller with the authority to prescribe, adopt, and enforce rules relating to the administration and enforcement of the provisions of Tax Code, Title 2.

The amendment implements Tax Code, §111.103

§3.5.Waiver of Penalty or Interest.

(a) Procedure for requesting waiver, audits.

(1) Penalty or interest on an audit liability may be waived if the taxpayer exercised reasonable diligence to comply with the tax laws of this state. A request to waive penalty or interest will be presumed in all cases governed by this subsection.

(2) The comptroller has delegated to the audit manager the initial authority to waive penalty and interest in appropriate cases. At the exit conference, the taxpayer will be told whether any penalty or interest will be waived. At this conference the taxpayer may request the audit manager to reconsider his/her decision on penalty or interest waiver. When reviewing a waiver request, the audit manager will consider the factors enumerated in subsection (c) of this section for penalty waiver and will consider the factors enumerated in subsection (d) of this section for interest waiver.

(3) The taxpayer will be advised of the audit manager's acceptance or rejection of the request for waiver of penalty or interest in the audit cover letter sent with the copy of the audit schedules.

(4) If a taxpayer's request for waiver is denied at the audit level, the taxpayer may raise the issue as a contested case matter during either a refund or redetermination hearing.

(b) Procedure for requesting waiver, non-audit.

(1) The comptroller has delegated to the Revenue Accounting Division the initial authority to waive penalty and interest when returns and reports are filed past the due dates.

(2) Penalty or interest on a non-audit liability may be waived if the taxpayer exercised reasonable diligence to comply with the tax laws of this state. A written request stating the reasons penalty and interest should be waived must be sent to the comptroller's Revenue Accounting Division accompanied by supporting documentation. The comptroller may require the production of any additional documentation necessary to evaluate a request.

(3) When reviewing a penalty waiver request under this subsection, Revenue Accounting Division will consider the following factors regarding a taxpayer's account and [ The Revenue Accounting Division ] will inform the taxpayer of the division's decision to accept or reject [ regarding ] the penalty waiver request [ after considering ]:

(A) whether the taxpayer is current in the filing of all returns;

(B) whether the taxpayer is current in the payment of all taxes and fees due the state;

(C) whether penalty has been waived on other occasions;

(D) why penalty was previously waived or denied;

(E) whether the taxpayer has a good record of timely filing and paying past returns; and

(F) whether the taxpayer has taken the necessary steps to correct the problem for future filings.

(4) When reviewing an interest waiver request under this subsection, [ The ] Revenue Accounting Division will consider the factors enumerated in subsection (d) of this section and will inform the taxpayer of the division's decision to accept or reject [ regarding ] the interest waiver request [ after considering the factors listed in subsection (d) of this section. ]

(5) A taxpayer may request an administrative appeal with the Revenue Accounting Division of a denial of a waiver request within ten calendar days from the date of written notification of the denial. Such a request for an administrative appeal must be in writing and must state the reasons the taxpayer disagrees with the denial of the waiver. [ contain all new ] New or additional documentation upon which the taxpayer relies for support should be submitted with the written request for an administrative appeal .

(6) The taxpayer will be sent written notification from the Revenue Accounting Division of the disposition of the appeal within 30 days of either the comptroller's receipt of the request for an appeal or the comptroller's receipt of all additional information requested from the taxpayer in relation to the appeal.

(7) If a taxpayer's request for waiver is denied by the Revenue Accounting Division, the taxpayer may raise the issue as a contested case matter during either a refund or redetermination hearing.

(8) When reviewing Revenue Accounting Division's denial of a penalty waiver request, the comptroller in a contested case will consider the factors enumerated in paragraph (3) of this subsection.

(c) Penalty. When reviewing the audit manager's denial of a penalty waiver request [ under subsection (a) of this section or in a contested case ], the comptroller in a contested case will consider the following factors regarding a taxpayer's account [ will be considered ]:

(1) the taxpayer's audit history;

(2) the tax issues involved;

(3) a change in comptroller policy during the audit period;

(4) size and sophistication of the taxpayer;

(5) whether tax was collected but not remitted;

(6) whether returns were timely filed;

(7) completeness of records;

(8) delinquencies in other taxes; and

(9) reliance on advice provided by the comptroller's office which caused imposition of penalty and interest.

(d) Interest. When reviewing an interest waiver request under subsections (a) or (b) of this section or in a contested case, the following factors regarding a taxpayer's account will be considered:

(1) undue delay caused by comptroller personnel;

(2) reliance on advice provided by the comptroller's office which caused imposition of penalty and interest; and

(3) natural disasters.

This agency hereby certifies that the proposal has been reviewed by legal counsel and found to be within the agency's legal authority to adopt.

Filed with the Office of the Secretary of State on March 1, 2004.

TRD-200401645

Martin Cherry

Chief Deputy General Counsel

Comptroller of Public Accounts

Earliest possible date of adoption: April 11, 2004

For further information, please call: (512) 475-0387


Subchapter F. MOTOR VEHICLE SALES TAX

34 TAC §3.96

The Comptroller of Public Accounts proposes an amendment to §3.96, concerning imposition and collection of a surcharge on certain diesel-powered motor vehicles. The section is being amended to implement Tax Code §152.0215 as amended by House Bill 1365 of the 78th Legislature, 2003, effective July 1, 2003. The surcharge now applies to the purchase or use of all diesel-powered motor vehicles with a gross registered weight of more than 14,000 pounds.

Subsection (a) is amended to include all model years and vehicles purchased out of state. Subsection (b) is amended to specify surcharge rates by model year. New subsection (f) addresses credit for tax paid to another state. Other amendments are for clarity.

James LeBas, Chief Revenue Estimator, has determined that for the first five-year period the rule will be in effect, there will be no significant revenue impact on the state or units of local government.

Mr. LeBas also has determined that for each year of the first five years the rule is in effect, the public benefit anticipated as a result of enforcing the rule will be in providing additional information regarding tax responsibilities. This rule is adopted under Tax Code, Title 2, and does not require a statement of fiscal implications for small businesses. There is no significant anticipated economic cost to individuals who are required to comply with the proposed rule.

Comments on the proposal may be submitted to Bryant K. Lomax, Manager, Tax Policy Division, P.O. Box 13528, Austin, Texas 78711.

This amendment is proposed under Tax Code, §111.002, which provides the comptroller with the authority to prescribe, adopt, and enforce rules relating to the administration and enforcement of the provisions of Tax Code, Title 2.

The amendment implements Tax Code, §152.0215

§3.96.Imposition and Collection of a Surcharge on Certain Diesel Powered Motor Vehicles.

(a) Definitions. The following words and terms, when used in this section, shall have the following meaning, unless the context clearly indicates otherwise.

(1) Motor vehicle subject to surcharge--A motor vehicle that is[ : ]

[ (A) ] diesel powered and [ ; ]

[ (B) ] registered with a gross vehicle weight in excess of 14,000 pounds . [ ; and ]

[ (C) a 1996 model year or earlier.]

(2) Lease--an agreement, other than a rental, whereby an owner of a motor vehicle gives exclusive use of the vehicle to another for consideration for a period that is more than 180 days.

(3) Rental--an agreement whereby:

(A) the owner of a motor vehicle gives exclusive use of the vehicle to another for consideration for a period that is 180 days or less;

(B) the original manufacturer of a motor vehicle gives exclusive use of the motor vehicle to another for consideration; or

(C) the owner of a motor vehicle gives exclusive use of the vehicle to another for re-rental purposes.

(4) Surcharge--A fee imposed [ of 2.5% of the total consideration paid ] on a [ Texas ] retail sale or use in this state of a motor vehicle described in paragraph (1) of this subsection. The surcharge is imposed by Tax Code, §152.0215, for the benefit of the Texas Emission Reduction Plan Fund as provided in Health and Safety Code, §386.251.

(b) Payment, calculation, collection and remittance. Except as provided in subsection (c) of this section, the surcharge is paid, calculated, collected, and remitted in the same manner as the tax imposed on a Texas sale as provided in Tax Code, Chapter 152, and §3.74 of this title (relating to Seller Responsibility). The fee is 1.0% of the total consideration paid for a motor vehicle subject to surcharge that is a model year 1997 or later, or 2.5% on a motor vehicle subject to surcharge that is a model year 1996 or earlier.

(c) Motor vehicles purchased for rental or lease.

(1) Rental. A person who purchases or brings into [ in ] Texas a motor vehicle for rental must pay the surcharge at the time of registration and titling. Payment of the surcharge cannot be deferred even if the purchaser is allowed to defer the motor vehicle sales and use tax. The surcharge is not due on the rental receipts paid to the motor vehicle owner.

(2) Lease. A person who purchases or brings into Texas a motor vehicle [ in Texas ] for lease must pay the surcharge based on the total consideration paid by the owner at the time of registration and titling. The surcharge is not due on the lease receipts paid to the motor vehicle owner.

(d) A motor vehicle described in subsection (a)(1) of this section that is brought into Texas for use by a new resident of this state is subject to the surcharge.

(e) [ (d) ] Exemptions. The exemptions provided in Tax Code, Subchapter E, Chapter 152, apply to the surcharge.

(f) The surcharge may not be offset by sales or use tax paid to other states on the purchase of a motor vehicle subject to the surcharge.

(g) [ (e) ] Expiration. The surcharge expires September 30, 2008. The surcharge is not due on vehicles sold or used in Texas [ retail sales ] after that date [ are not subject to the surcharge ].

This agency hereby certifies that the proposal has been reviewed by legal counsel and found to be within the agency's legal authority to adopt.

Filed with the Office of the Secretary of State on March 1, 2004.

TRD-200401646

Martin Cherry

Chief Deputy General Counsel

Comptroller of Public Accounts

Earliest possible date of adoption: April 11, 2004

For further information, please call: (512) 475-0387


Subchapter K. HOTEL OCCUPANCY TAX

34 TAC §3.161

The Comptroller of Public Accounts proposes an amendment to §3.161, concerning definitions, exemptions, and exemption certificate. This amendment incorporates legislative changes in House Bill 2424, 78th Legislature, 2003, which amended Tax Code, Chapter 156, to add the requirement that public and private institutions of higher education be Texas public and private institutions of higher education to be exempt from state hotel occupancy tax; to provide good faith acceptance, with proper documentation, of hotel occupancy tax exemption certificates by persons required to collect the tax; and to require the comptroller to produce and maintain a list of organizations that have received a letter of exemption under §156.102, and make the list available on the comptroller's Internet Web site.

Subsection (a)(2) is amended to provide that public and private institutions of higher education from other states and countries do not meet the requirements for exemption. Subsection (c)(2) is added to prescribe the support documentation required to accept an exemption certificate in good faith, including a printed copy of the comptroller's Internet Web site listing the organization as exempt for hotel tax when appropriate. The remainder of the section is renumbered accordingly.

James LeBas, Chief Revenue Estimator, has determined that for the first five-year period the rule will be in effect, there will be no significant revenue impact on the state or units of local government.

Mr. LeBas also has determined that for each year of the first five years the rule is in effect, the public benefit anticipated as a result of enforcing the rule will be in providing additional information regarding tax responsibilities. This rule is adopted under Tax Code, Title 2, and does not require a statement of fiscal implications for small businesses. There is no significant anticipated economic cost to individuals who are required to comply with the proposed rule.

Comments on the proposal may be submitted to Bryant K. Lomax, Manager, Tax Policy Division, P.O. Box 13528, Austin, Texas 78711.

This amendment is proposed under Tax Code, §111.102, which provides the comptroller with the authority to prescribe, adopt, and enforce rules relating to the administration and enforcement of the provisions of Tax Code, Title 2.

The amendment implements Tax Code, §156.102(b) and §156.104.

§3.161.Definitions, Exemptions, and Exemption Certificate.

(a) Definitions. The following words and terms, when used in this subchapter, shall have the following meanings, unless the context clearly indicates otherwise.

(1) Charitable or eleemosynary organization--A nonprofit organization devoting all or substantially all of its activities to the alleviation of poverty, disease, pain, and suffering by providing food, clothing, drugs, treatment, shelter, or psychological counseling directly to indigent or similarly deserving members of society with its funds derived primarily from sources other than fees or charges for its services. If the organization engages in any substantial activity other than the activities described in this section, it will not be considered as having been organized for purely public charity, and therefore, will not qualify for exemption under this provision. No part of the net earnings of the organization may inure to the benefit of any private party or individual other than as reasonable compensation for services rendered to the organization. Some examples of organizations that do not meet the requirements for exemption under this definition are fraternal organizations, lodges, fraternities, sororities, service clubs, veterans groups, mutual benefit or social groups, professional groups, trade or business groups, trade associations, medical associations, chamber of commerce, and similar organizations. Even though not organized for profit and performing services that are often charitable in nature, these types of organizations do not meet the requirements for exemption under this provision.

(2) Educational organization--A nonprofit organization or governmental entity whose activities are devoted solely to systematic instruction, particularly in the commonly accepted arts, sciences, and vocations, and has a regularly scheduled curriculum, using the commonly accepted methods of teaching, a faculty of qualified instructors, and an enrolled student body or students in attendance at a place where the educational activities are regularly conducted. An organization that has activities consisting solely of presenting discussion groups, forums, panels, lectures, or other similar programs, may qualify for exemption under this provision, if the presentations provide instruction in the commonly accepted arts, sciences, and vocations. The organization will not be considered for exemption under this provision if the systematic instruction or educational classes are incidental to some other facet of the organization's activities. No part of the net earnings of the organization may inure to the benefit of any private party or individual other than as reasonable compensation for services rendered to the organization. Some examples of organizations that do not meet the requirements for exemption under this definition are professional associations, business leagues, information resource groups, research organizations, support groups, home schools, and organizations that merely disseminate information by distributing printed publications. Entities that are defined in the Education Code, §61.003, as Texas public or private "institutions of higher education" are recognized for exemption under this provision. Included in the definition of "institutions of higher education" is any public technical institute, public junior college, public senior college or university, medical or dental unit, public state college, or other agency of higher education as identified in Education Code, §61.003. A Texas private "institution of higher education" is a private or independent university or college that is organized under the Texas Non-Profit Corporation Act; exempt from taxation under Article VIII, Section 2, of the Texas Constitution and Section 501 (c)(3) of the Internal Revenue Code of 1986 (26 U.S.C. Section 501); and accredited by the Southern Association of Colleges and Schools [ are state and private universities and colleges ]. Beginning October 1, 2003, public and private "institutions of higher education" from other states or countries do not meet the requirements for exemption under this provision.

(3) Hotel--Any building or buildings in which members of the public obtain sleeping accommodations for a consideration. The term includes, in addition to the buildings listed in Tax Code, §156.001, manufactured homes, skid mounted bunk houses, residency inns, condominiums, cabins, and cottages.

(4) Permanent Resident--A person who has the right to use or occupy a room or space in a hotel for at least 30 consecutive days without interruption. A person may be an individual, organization, or entity.

(5) Private Club--An organization that provides members entertainment, recreation, sport, dining, or social facilities and assesses dues, initiation fees, and other charges for special privileges or status not available to the general public.

(6) Religious organization--A nonprofit organization that is an organized group of people regularly meeting for the primary purpose of holding, conducting and sponsoring religious worship services, according to the rights of their sect. The organization must be able to provide evidence of an established congregation showing that there is an organized group of people regularly attending these services. An organization that supports and encourages religion as an incidental part of its overall purpose, or one whose general purpose is furthering religious work or instilling its membership with a religious understanding, will not qualify for exemption under this provision. No part of the net earnings of the organization may inure to the benefit of any private party or individual other than as reasonable compensation for services rendered to the organization. Some examples of organizations that do not meet the requirements for exemption under this definition are conventions or associations of churches, evangelistic associations, churches with membership consisting of family members only, missionary organizations and groups who meet for the purpose of holding prayer meetings, bible study or revivals.

(b) Exemptions. This subsection deals with exemptions from the state hotel occupancy tax. For information on city and county hotel taxes, contact the affected city or county.

(1) Religious, charitable, and educational organizations and their employees, including college and university personnel, traveling on official business of the organization are exempt from payment of hotel occupancy tax.

(2) State officials, judicial officers, heads of state agencies, the Executive Director of the Legislative Council, the Secretary of the Senate, state legislators, legislative employees, members of state boards and commissions, and designated state employees of the State of Texas who present a Hotel Tax Exemption Photo Identification Card when traveling on official state business are exempt from the hotel occupancy tax. State agency, institution, board, or commission employees who have not been issued a Hotel Tax Exemption Photo Identification Card must pay the hotel occupancy tax. The hotel tax paid by the state or reimbursed to a state employee may be refunded as provided in §3.163 of this title (relating to Refund of Hotel Occupancy Tax). For the purpose of claiming an exemption, a Hotel Tax Exemption Photo Identification Card includes:

(A) any photo identification card issued by a state agency that states "EXEMPT FROM HOTEL OCCUPANCY TAX, under Tax Code, §156.103(d)", or similar wording; or

(B) a Hotel Tax Exemption Card that states "when presented with a photo identification card issued by a Texas agency, the holder of this card is exempt from state, municipal, and county hotel occupancy tax, Tax Code, §156.103(d)", or similar wording.

(3) The United States government and its employees traveling on official business representing the United States government are exempt from the hotel occupancy tax.

(4) Diplomatic personnel of a foreign government who present an appropriate Tax Exemption Card issued by the United States Department of State are exempt from the tax.

(5) If an exemption applies, then the organization or individual claiming exemption must present an exemption certificate to the hotel.

(6) Permanent residents are exempt from payment of hotel occupancy tax.

(A) A permanent resident is exempt beginning on:

(i) the first day for which the resident has entered into a written agreement with the hotel or has given a written notice to the hotel of the resident's intent to use or occupy a room or space in the hotel for the next 30 or more consecutive days and the resident actually stays for at least the next 30 consecutive days; or

(ii) the first day after the 30th consecutive day of the stay, if the resident neither gave written notice of intent to stay, nor entered into any written agreement with the hotel. For example, if a person does not notify the hotel that he intends to stay for at least 30 days, but stays 35 days, then the person is exempt from hotel tax from the 31st day through the 35th day, but tax is due on the first 30 consecutive days of the occupancy.

(B) The permanent resident exemption ends when an interruption in the right to use or occupy the room or space occurs.

(C) Permanent residents are not required to physically occupy a room or space.

(D) Permanent residents may have the right to use or occupy different rooms in the same hotel without loss of the permanent resident exemption.

(E) The permanent resident exemption applies to the lowest number of rooms in a written notice, agreement, or contract for a range of rooms plus the number of rooms that qualify for the permanent resident exemption under subsection (b)(6)(A)(ii) of this section.

Figure: 34 TAC §3.161 (b)(6)(E) (No change)

(c) Exemption certificate.

(1) Any organization or individual claiming exemption from the payment of hotel occupancy tax must furnish the hotel with a signed exemption certificate.

(2) The rental of a room or space in a hotel is exempt from tax if the person required to collect the tax receives, in good faith from a guest, a properly completed exemption certificate stating that the guest qualifies for exemption under Tax Code §156.102 or §156.103 or other law. The exemption certificate must be supported by the following documentation:

(A) for persons traveling on official business of the federal government, a valid government identification card;

(B) for state officials exempted by Tax Code §156.103(d), a Hotel Tax Photo Identification Card, as described in subsection (b)(2)(A) or (B) of this rule;

(C) for diplomatic personnel of a foreign government, the appropriate Tax Exemption Card issued by the United States Department of State;

(D) for persons traveling on official business of a charitable, educational, or religious organization, as defined in subsection (a)(1), (2) or (6) of this rule:

(i) a letter of hotel tax exemption issued by the Comptroller of Public Accounts; or

(ii) verification that the organization is on the comptroller's list of entities that have been provided a letter of exemption; such as, a printed copy of the Comptroller's Internet Web site listing the organization as exempt for hotel tax.

(E) For persons traveling on official business of an organization exempt by law other than Tax Code Chapter 156:

(i) a letter of hotel tax exemption issued by the Comptroller of Public Accounts; or

(ii) verification that the organization is on the comptroller's list of entities that have been provided a letter of exemption.

(F) The manner of payment by an employee of an exempt organization does not affect the exemption. To claim an exemption a nonemployee traveling on behalf of an exempt organization must pay the hotel directly with the organization's funds, by organization check, organization credit card, or direct billing to the organization by the hotel.

(3) [ (2) ] A hotel claiming exemption of its receipts from hotel occupancy tax must provide proof that the receipts were exempt, either through exemption certificates or other competent evidence.

(4) [ (3) ] Certain entities that are exempt from hotel tax may be issued identification numbers for administrative purpose only. The Comptroller may issue a tax number to an entity that is not exempt from Hotel Tax, and a tax number does not guarantee that an organization is exempt from Hotel Tax. An organization is not required to provide an identification number on the Hotel Tax Exemption Certificate [ Exemption numbers or tax numbers do not exist for purposes of the hotel occupancy tax ].

(5) [ (4) ] The exemption certificate must be substantially in the form herein adopted by reference. Copies of the certificate are available for inspection at the office of the Texas Register or may be obtained from the Comptroller of Public Accounts, P.O. Box 13528, Austin, Texas 78711. Copies may also be requested by calling our toll-free number 1-800-252-1385. In Austin, call 463-4600. (From a Telecommunication Device for the Deaf (TDD) only, call 1-800-248- 4099 toll free. In Austin the local TDD number is 463-4621.) Taxpayers may download copies at www.window.state.tx.us.

(d) Exclusions.

(1) Dormitories and other housing facilities owned or leased and operated by institutions of higher education as defined in subsection (a)(2) and used to provide sleeping accommodations for persons engaged in educational programs or activities at the institutions are excluded from the definition of a hotel in Tax Code, §156.001, and their rentals are not subject to tax. Hotels owned or leased and operated by institutions of higher education, however, are not excluded and their rentals are subject to tax.

(2) Private clubs as defined in subsection (a)(5) do not collect tax on rentals of rooms to members. Tax is due, however, on the rental of rooms to nonmembers.

This agency hereby certifies that the proposal has been reviewed by legal counsel and found to be within the agency's legal authority to adopt.

Filed with the Office of the Secretary of State on March 1, 2004.

TRD-200401642

Martin Cherry

Chief Deputy General Counsel

Comptroller of Public Accounts

Earliest possible date of adoption: April 11, 2004

For further information, please call: (512) 475-0387


Subchapter O. STATE SALES AND USE TAX

34 TAC §3.325

The Comptroller of Public Accounts proposes an amendment to §3.325, concerning refunds, interest, and payments under protest. The proposed amendment implements legislative changes and codification of existing policies made by House Bill 2425, 78th Legislature, 2003, that describe when and how persons may obtain a refund of tax paid in error. Provisions relating to limitations in subsection (a) are reorganized in new subsection (c) and the remaining subsections have been relettered accordingly.

James LeBas, Chief Revenue Estimator, has determined that for the first five-year period the rule will be in effect, there will be no significant revenue impact on the state or units of local government.

Mr. LeBas also has determined that for each year of the first five years the rule is in effect, the public benefit anticipated as a result of enforcing the rule will be in providing additional information regarding tax responsibilities. This rule is adopted under Tax Code, Title 2, and does not require a statement of fiscal implications for small businesses. There is no significant anticipated economic cost to individuals who are required to comply with the proposed rule.

Comments on the proposal may be submitted to Bryant K. Lomax, Manager, Tax Policy Division, P.O. Box 13528, Austin, Texas 78711.

This amendment is proposed under Tax Code, §111.002, which provides the comptroller with the authority to prescribe, adopt, and enforce rules relating to the administration and enforcement of the provisions of Tax Code, Title 2.

The amendment implements Tax Code §§171.051-171.087

§3.325.Refunds, Interest, and Payments Under Protest.

(a) [ Tax paid to state. ] A [ Any ] person who has paid tax in error to the state or to a permitted seller [ , his attorney, assignee, executor, or administrator ] may request [ from the comptroller ]a refund of [ any ]tax paid in error [ remitted to the state but that was not due ].

(1) A person who does not have a sales and use tax permit and who has paid tax in error to a permitted seller may request a refund from only the permitted seller to whom the tax was paid. The permitted seller who refunds tax to a purchaser may claim a refund with the comptroller as provided by subsection (b).

(2) A sales and use tax permit holder who has paid tax in error directly to the comptroller may request from the comptroller a refund of the tax paid in error.

(3) A sales and use tax permit holder who has paid tax in error to another permitted seller may request from the comptroller or the seller a refund of tax paid in error.

(4) A person who requests a refund from the comptroller must:

(A) submit a claim made in writing and must state fully and in detail the specific grounds upon which the claim is based;

(B) indicate the period for which the claimed overpayment was made;

(C) submit the claim within the applicable limitations period as provided subsection (c); and

(D) submit supporting documentation required by the comptroller.

[(1) A claim for refund of an amount paid pursuant to a deficiency determination is timely for all transactions that are included in the deficiency determination if made in accordance with subparagraphs (B) or (C) of this paragraph. A claim for refund for items that are not included in a deficiency determination must be made in accordance with subparagraph (A) of this paragraph. The refund request must be made within:]

[(A) four years from the date on which the tax was due and payable as defined in Tax Code, §151.401; or]

[(B) six months after a determination for the periods for which refund is claimed becomes final; or]

[(C) six months after any determination would have become final had payment not been made before the due date.]

[(2) Before the expiration of the statute of limitations, the comptroller and a taxpayer may agree in writing to an extension of the statute of limitations.]

[(3) An extension of the statute of limitations applies only to the periods that are specified in the agreement. Any assessment or refund request that pertains to periods for which limitations have been extended must be made prior to the expiration date of the agreement. Following expiration of the agreement, the statute of limitations applies to subsequent assessments and refund requests as if no extension had been agreed.]

[(4) The request for refund must be made in writing and must state the specific grounds upon which the claim is founded. The request must also indicate the period for which the claimed overpayment was made.]

[(5) In determining the statute of limitations for filing a refund claim, the time during which an administrative proceeding is pending before the comptroller for the same period is not counted. A taxpayer may not file a sales tax refund claim for the same transaction and for the same time period as a refund claim previously denied.]

[(6) Failure to file a claim within the limitation prescribed by this section constitutes a waiver of any demand against the state on account of the overpayment.]

(b) [ Tax paid to seller. A person who remits tax to a permitted seller may request from the seller or the comptroller a refund of Texas tax paid in error. ]The following procedures must be used to request a refund from the comptroller .

(1) Seller who requests a refund from the comptroller.

(A) Before a seller refunds to a purchaser tax collected in error, the seller must obtain from the purchaser a properly completed exemption or resale certificate that meets all the requirements of §3.285 of this title (relating to Sales for Resale; Resale Certificate) and §3.287 of this title (relating to Exemption Certificates). The seller must retain the certificate to document the basis for the refund.

(B) After the seller has refunded or, with the purchaser's written consent, credited the tax to the account of the purchaser, the seller may then seek reimbursement from the state in accordance with the procedures that are outlined in subsection (a) of this section or take a credit on the seller's next return in the amount refunded or credited to the account of the purchaser.

(2) A permitted purchaser who requests a refund from the comptroller.

(A) A permitted purchaser who requests a refund from the comptroller must submit to the comptroller a written request that states the basis for the refund and includes the following information:

(i) the seller's name, address, and either the sales tax permit number or information that will enable the comptroller to identify the seller's sales tax permit number;

(ii) the invoice number, if applicable;

(iii) the date of purchase;

(iv) a description of the item purchased;

(v) the specific basis for the refund;

(vi) information that identifies the local taxing authorities for which tax was paid; and

(vii) a statement or reasonable estimate of the amount of the tax refund requested.

(B) The comptroller may require a person to submit additional information to verify the refund claim. The person must show to the satisfaction of the comptroller that the refund is due and make available to the comptroller any documentation that the comptroller requires to process the refund.

(C) A permitted purchaser[ who holds a sales and use tax permit ] may amend the return for the period in which the overpayment was made or file a refund claim with the comptroller for sales tax paid in error to a seller. The refund claim must identify the period in which the tax was originally paid. The purchaser must retain, for the period required in Tax Code, Chapter 111, all documentation that is necessary to support the credit.

(c) A claim for refund must be made within the limitations periods.

(1) A claim for refund must be made within four years from the date on which the tax was due and payable as provided by §151.401, Tax Code.

(2) A claim for refund for tax paid pursuant to a deficiency determination must be made by the later of:

(A) four years from the date on which the tax was due and payable; or

(B) six months after the date on which the deficiency determination for the periods becomes final.

(3) If the comptroller and a taxpayer have agreed in writing to extend the limitations period, then a claim for refund must be made before the expiration of the extended period in the agreement. An extension of the statute of limitations applies only to the periods that are specified in the agreement. An expired agreement to extend the statue of limitations has no effect and the statue of limitations for subsequent assessments and refund requests is determined as if no extension had been authorized. For the limitations period for assessments, see §3.339 (relating to Statute of Limitations)

(4) A redetermination or refund proceeding does not toll the statute of limitations, except for the issues contested.

(5) Failure to file a claim within the limitations prescribed by this section constitutes a waiver of any demand against the state on account of the overpayment.

(d) [ (c) ] Interest.

(1) Except as provided by paragraphs (2) and (3) of this subsection, in a comptroller's final decision on a claim for refund or in an audit, interest accrues at the rate that is set in Tax Code, §111.060, on the amount that is found to be erroneously paid:

(A) beginning on the later of 60 days after the date of payment or the due date of the tax report; and

(B) ending on, as determined by the comptroller, either:

(i) the date of allowance of credit that results from a final decision that the comptroller has issued, or from an audit; or

(ii) a date that is not more than 10 days before the date of the refund warrant.

(2) The interest rate for a refund that is granted for a period for which a report is due after December 31, 1999, is the rate set in Tax Code, §111.060. A refund for a period for which a report is due before January 1, 2000, does not accrue interest.

(3) Credits taken by a taxpayer on the taxpayer's return do not accrue interest.

(4) No taxes, penalties, or interest will be refunded to a person who has collected the taxes from another person until all taxes are first refunded to the party from whom they were collected.

(e) Denial of refund.

(1) If the comptroller determines that the claim for refund cannot be granted either partially or fully, then the comptroller will notify the claimant of the denial. Claimant may request a refund hearing within 30 days of the denial.

(2) A person may not refile a refund claim for the same transaction or item, tax type, period, and ground or reason that was previously denied by the comptroller.

(f) [ (d) ] Payments under protest. A person who intends to file suit under Tax Code, Chapter 112, Subchapter B, must submit to the comptroller a letter of protest with the payment of the tax that is the subject of the protest. See subsection (e) of §3.9 of this title (relating to Electronic Filing of Returns and Reports; Electronic Transfer of Certain Payments by Certain Taxpayers). The letter of protest must state fully and in detail every reason that the taxpayer contends that the assessment is unlawful or unauthorized, and must accompany the payment. If the payment and letter of protest do not accompany one another, the payment will not be deemed to have been made under protest. For the taxpayer's convenience, the comptroller will advise the taxpayer of the amount of payment under protest that the comptroller has received and the date of the payment.

This agency hereby certifies that the proposal has been reviewed by legal counsel and found to be within the agency's legal authority to adopt.

Filed with the Office of the Secretary of State on March 1, 2004.

TRD-200401643

Martin Cherry

Chief Deputy General Counsel

Comptroller of Public Accounts

Earliest possible date of adoption: April 11, 2004

For further information, please call: (512) 475-0387


34 TAC §3.331

The Comptroller of Public Accounts proposes an amendment to §3.331, concerning transfer of common interests in tangible personal property; intercorporate services. The proposed amendments consolidates subsections (a) and (b) and reletters other subsections accordingly. Subsection (b) restates the exemption for joint research and development venture as provided by Tax Code §151.348. Subsection (c) updates and clarifies the current policy of intercorporate exemption as provided by Tax Code 151.346. Other amendments are made for clarity.

James LeBas, Chief Revenue Estimator, has determined that for the first five-year period the rule will be in effect, there will be no significant revenue impact on the state or units of local government.

Mr. LeBas also has determined that for each year of the first five years the rule is in effect, the public benefit anticipated as a result of enforcing the rule will be in providing additional information regarding tax responsibilities. This rule is adopted under Tax Code, Title 2, and does not require a statement of fiscal implications for small businesses. There is no significant anticipated economic cost to individuals who are required to comply with the proposed rule.

Comments on the proposal may be submitted to Bryant K. Lomax, Manager, Tax Policy Division, P.O. Box 13528, Austin, Texas 78711.

This amendment is proposed under Tax Code, §111.002, which provides the comptroller with the authority to prescribe, adopt, and enforce rules relating to the administration and enforcement of the provisions of Tax Code, Title 2.

The amendment implements Tax Code, §151.346

§3.331.Transfers of Common Interests in Tangible Personal Property; Intercorporate Services.

(a) Transfer of common interests.

(1) [ (a) ] Sales or use tax is not due when an interest in tangible personal property is sold to a purchaser who, either before or after the sale, owns a joint or undivided interest in the tangible personal property with the seller.

(2) [ (b) ] In order for the sale to be exempt, the following requirements must be met.

(A) [ (1) ] The seller must have paid sales or use tax on the tangible personal property when it was purchased.

(B) [ (2) ] The sale must be made pursuant to the terms of a good faith contractual relationship between the seller and the purchaser. Good faith contractual relationship means a legal relationship established between two or more persons created for considerations other than the avoidance of the limited sales and use tax.

(C) [ (3) ] It is necessary that the purchaser, either before or after the sale, own a joint or undivided interest in the property with the seller. The joint ownership transfer exemption does not apply to sales between related corporations or other entities if [ where ] the only joint ownership is the ultimate ownership of the corporation stock.

(b) [ (c) ] Research and development ventures. Sales and use tax is not due on tangible personal property [ Items which are ] sold by a joint research and development venture as defined by 15 United States Code §4301 to a participating entity if the tangible personal property is created, developed, or substantially modified by or for the joint research and development venture [ in connection with the venture are exempt from sales and use tax ].

(c) [ (d) ] Intercorporate services.

(1) Sales or use tax is not due on charges for taxable services if the seller and purchaser are [ between ] affiliated entities that are members of an affiliated group under 26 U.S.C. §1504, and if both entities [ corporations which qualify to ] report their income to the Internal Revenue Service on a single consolidated income tax return with at least one corporation that is a member [ other members ] of the affiliated group for the tax year in which the taxable service is provided. If either the seller or the purchaser elects to file a separate federal income tax return even though it is eligible to file a consolidated federal income tax return with other members of the affiliated group, the exemption provided by this subsection does not apply.

(2) Sales or use tax is not due on charges for taxable services if both the seller and purchaser are entities classified as members of an affiliated group under 26 U.S.C. §1504, but either the seller or purchaser or both cannot file a consolidated federal income tax return because of the exclusions provided by 26 U.S.C. §1504(b). [ For the purposes of this subsection, "affiliated corporation" includes a corporation that would be classified as a member of an affiliated group under 26 United States Code §1504 but for the exclusion provided by that section. ]

(3) The exemption provided by this subsection does not apply to sales of tangible personal property between affiliated corporations or sales of [ . Neither does the exemption apply to ] services that were taxable before September 2, 1987. The following services [ Services that ] were taxable [ subject to sales and use tax ] before September 2, 1987[ , and which are taxable when provided among affiliated entities, include ]:

(A) amusement services;

(B) cable television services;

(C) personal services;

(D) motor vehicle parking and storage;

(E) the repair, remodeling, maintenance, or restoration of tangible personal property except maintanance of computer software and those services excluded from tax by [ . (See the exception in the ] Tax Code, §151.0101(a)(5)[ ) ]; and

(F) telecommunications services.

(4) A seller of a taxable service must pay sales or use tax on its purchase of tangible [ Tangible ] personal property that the seller transfers [ is transferred ] as an integral part of the taxable [ a ] service if the sale of the taxable service is exempt from sales tax [ exempted ] under this subsection [ may not be purchased for resale by the providing company ]. The seller may not claim a sale for resale exemption.

(5) A seller of a taxable service must pay sales or use tax on its purchase of a taxable service that the seller transfers as an integral part of the taxable service sold if the sale of the taxable service is [ Services that are ] exempt from sales tax under this subsection [ may not be purchased for resale by the providing company ]. The seller may not claim a sale for resale exemption.

(6) When a contract contains charges for taxable items and charges for services that qualify for exemption under this subsection, the total charge will be taxable unless the charge for taxable items is separately stated to the customer.

This agency hereby certifies that the proposal has been reviewed by legal counsel and found to be within the agency's legal authority to adopt.

Filed with the Office of the Secretary of State on March 1, 2004.

TRD-200401644

Martin Cherry

Chief Deputy General Counsel

Comptroller of Public Accounts

Earliest possible date of adoption: April 11, 2004

For further information, please call: (512) 475-0387