Fujifilm Unit Loses Bid for Washington Tax Refund on Appeal

A Fujifilm Holdings Corp. unit failed to convince a Washington appeals court Tuesday that it’s entitled to a $7.78 million tax refund as a reseller rather than a manufacturer.

A letter ruling the company requested from the Washington Department of Revenue doesn’t provide a safe harbor from manufacturer tax liability, the Washington Court of Appeals, Division II, ruled in an unpublished opinion.

The department properly classified SonoSite as a manufacturer “based on its ownership of the materials and machinery used in its manufacturing processes,” Judge Anne Cruser wrote for the three-judge panel.

Manufacturers are taxed on the value of ...