Washington Court of Appeals Affirms Denial of Taxpayer’s B&O Tax Refund Claim

The Washington Court of Appeals affirmed the Board of Tax Appeals’ denial of most of the taxpayer’s business and occupation tax refund claim. The dispute centered on whether income, from localization services the taxpayer, a consulting firm, provided to Microsoft, should be attributed to Washington for tax purposes. The Department of Revenue (DOR) apportioned payment for localization services the taxpayer performed for its client, Microsoft, from 2011-2015, as taxable income, stating the taxpayer’s customers received the benefit of the services in Washington. The taxpayer argued in its refund claim that the DOR improperly denied the refund by attributing income according ...