Washington Appeal Court Reverses Tax Ruling on Remote Title Insurance Services

The Washington Court of Appeals, Division 2, reversed the trial court’s decision in favor of the taxpayer, a title insurance company. The dispute arose when the Department of Revenue assessed taxes on the taxpayer’s remote title insurance and escrow services provided for Washington properties from out-of-state offices. The court interpreted RCW 82.32.730 and concluded that these sales should be sourced to Washington under subsection (1)(b), rather than to the out-of-state offices under subsection (1)(a) as the taxpayer had argued. The court reasoned that the statute prioritizes the location of the purchaser, not the seller, and that purchasers first use such ...