acting as an independent contractor for many persons using its server should not result in any foreign user having an office or other fixed place of business
in the U.
To the extent that a state applies its sales tax only to the transfer of tangible personal property, the sale or license of a packaged program should not be a taxable transaction if the program is transferred by remote telecommunications from the seller's place of business
to the purchaser's computer and the purchaser does not obtain possession of any tangible personal property, such as storage media, in the transaction.
Soliman deducted expenses relating to his home office, claiming the room was his principal place of business
under section 280A(c) (1) (A).
When a taxpayer's residence qualifies as his or her principal place of business
under section 280A(c)(1 )(A), daily transportation expenses paid or incurred between that residence and another work location in the same trade or business, regardless of whether the other work location is regular or temporary and regardless of the distance traveled.
If a taxpayer's residence is his or her principal place of business
under section 280A(c)(1)(A), he or she may deduct daily transportation expenses incurred between the residence and another work location in the same trade or business, regardless of whether the other work location is regular or temporary and regardless of the distance.
Under the Supreme Court's more restrictive facts-and-circumstances test, the two primary considerations used to determine whether a home office was a taxpayer's principal place of business
were the relative importance of the activities performed at each business location and the time spent at each place.
Curphey, 73 TC 766 (1980), the Tax Court held that daily transportation expenses incurred in a rental business by a dermatologist in going between an office in his residence and other work locations (the rental units) were deductible when the home office was his principal place of business
(see also John Gosling, TC Memo 1999-148, and Valerie Jean Genck, TC Memo 1998-105).
The home office must be the principal place of business
Delaware's broad definition of "holder" would encompass, for example, an LLC organized ("created") in Delaware but with a principal place of business
located in Montana, a state that follows the 1995 Uniform Act.
An exception to IRC section 280A stipulates the home office be the principal place of business
Dublin K67TR04 & having its principal place of business
at 40 Rivervalley Drive, Swords, Co.
As a place of business
used to meet with patients, clients or customers in the normal course of the taxpayer's trade or business; or
The concept of a principal place of business
has not been so easily determined, especially for taxpayers who do work at more than one location or do various parts of their job in different places.
Carlow & having its principal place of business
at market square, bagenalstown, co.
Fixed facility: A permanent establishment includes a fixed place of business
through which the resident carries on industrial or commercial activity.