California formalizes federal conformity rules and updates R&D tax credit
Interim IRS guidance clarifies bonus depreciation rules under OBBB. Learn what taxpayers should review now.
Energy Credits
Among the tax incentives and credits for investment into renewable energy, a new provision allowing certain transfers of energy credits
Excise Tax
1% excise tax
On certain stock repurchases and economically similar transactions.
SERVICE DETAILS
Navigate complexity with confidence
CohnReznick’s Commercial Real Estate Industry Practice serves as a trusted advisor, sought after for capital sourcing and transaction guidance, infrastructure advisory, tax and regulatory compliance support, operational improvement, property and investment management technology solutions, and market-focused business insights.
AICPA vs. PCAOB Audits
AICPA vs. PCAOB Audits

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Many of the biggest business challenges – technology, talent, operations, risk, and growth – continue to grow in complexity. With the continuous innovation of technology solutions and new players entering the market, finding the right tools to support your business operations based on your industry, size, and specific needs is imperative to achieving long-term success.
There are tools available to automate and organize your processes and procedures, such as accounts payable and receivable, 1099 reporting, payroll processing, reporting, and sales and use tax reporting. The benefits of automation are vast, but it can be difficult to assess and prioritize the various use cases for those that would add the most value based on your company’s needs.
Benefits we've seen companies experience by implementing finance and accounting automation tools include:
- Increased productivity. Using technology to automate repetitive and time-consuming tasks allows for faster completion of deliverables, unlocking time to work on more value-added tasks and drive higher productivity. As an example, the use of optical character recognition (OCR) built within an accounts payable workflow solution will increase productivity and transparency for the accounts payable process.
- Cost management. Integrating automation tools to complete tasks accurately and consistently, in alignment with your current processes, can lead to lower operational and personnel costs and therefore increased profitability. For example, using a close management tool integrated with a quality assurance tool can help standardize and reduce the amount of time to complete month-end tasks.
- Improved quality. Standardized processes can minimize the risks of human error and improve the quality of outputs as the work is done in a repeatable way according to predefined standards. Leveraging system lookup and data validation through a point solution tool can help minimize manual data entry errors.
- Time for strategic initiatives. Tasks requiring precision such as data entry and complex calculations can be automated, freeing up resources to focus on tasks requiring creative thought, problem-solving, and client service. When you increase automation through the transactional level by reducing keystrokes and various lookups you can have your staff spend more time on value-added tasks versus being heads-down on data entry.
- Scalable processes. Automating standard processes enables you to scale your business for increased workloads without increasing staff. These tools can grow with you, giving you the ability to upgrade to other platforms or integrate additional applications with minimal disruption. It is important to look for a technology stack that is flexible and scalable to your business. A robust general ledger system will enable you to support your business as you grow and become more complex.
- Financial insights. Budgeting and forecasting tools not only help you stay on track but also enable you to gain insights into near-future performance, in real time. This allows your organization to pivot, collaborate, and adjust resources that support a service or product showing unexpected success or decline. There are many budgeting and forecasting tools that are affordable and provide simple integrations with your general ledger.
- Response time. Automated tools operate on a global scale and run 24/7, enabling continuous processes and services essential for tasks requiring constant monitoring or quick response times. When selecting a technology stack, leverage a cloud-based system that your teams can easily access securely from across the globe.
- Risk mitigation. Automation can significantly decrease risks as it follows standard processes and security protocols that are created with your risk profile and governance needs in mind. You will want to ensure that the tools you use are properly vetted from a security and compliance perspective.
- Product development. By automating time-consuming processes, teams can redirect their focus to projects that require innovation and creativity, leading to the development of new products and services to grow your business. There is a renaissance of new products and tools being introduced to the finance function. Identify a team within your practice to evaluate and assess the latest technologies to determine which may be the right fit for your organization.
- Technology investment. Cloud-based technology can save you money by virtualizing your hardware. It can decrease or eliminate the costs of servers, data centers, and networking resources by relocating them to the cloud.
A key strength is knowing when and where to apply automation tools, and where to limit new technologies due to cost/benefit analysis and prioritization. Having an open and transparent conversation with your company’s technology and business unit leaders about your options and recommendations will help drive agreement on the right decision for your organization.
Expertise throughout the Global Real Estate Ecoystem
From owners and developers to operators and investors — we understand the intricacies and objectives of each stakeholder across the Americas, EMEA, and Asia-Pacific. Our clients include:
- Hotels and resorts
- Industrial and land developers
- Multi-family housing builders
- Pension funds
- Property owners and operators
- Private equity funds
- Real estate developers
- REITs
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Community Development
Learn more about the economic benefits that projects such as MLB ballpark construction can bring to the surrounding neighborhood. View this content series to explore the latest strategies and tools for industry participants - whether you are an investor, lender, developer, or government agency,

Specialized services for commercial real estate organizations
In a dynamic industry like real estate, workflow is complicated — many dependencies and paths run not only parallel but can often cross at numerous critical points along the value chain. Basic operational needs may be ongoing, but unique circumstances and challenges must be met quickly and effectively to remain productive and ahead of the competition. CohnReznick has an array of offerings specific to companies involved in commercial real estate.
Our network is vast and our relationships are long-tenured. Among capital sources are private equity funds, pension funds, family offices, foreign and domestic banks, life insurance companies, endowments, and CMBS platforms. Throughout our firm’s history, we have connected clients with strong partners, unique sources of capital, and specialized advice in strategic joint ventures and asset-level equity and debt placement.
We provide cost segregation analysis so your organization can reclassify assets for faster depreciation — deferring taxes and increasing cash flows.
We streamline property management, optimize financial performance, and support growth initiatives. By using innovative processes and technology, we enhance efficiency and profitability across your portfolio. Our services facilitate compliance and improve financial reporting, helping you make informed investment decisions.
Improve the performance of your properties by aligning operations to strategy and optimizing critical business processes. Leveraging technology, CohnReznick helps clients streamline operations and identify opportunities, executing over 100 technology projects annually. Our solutions eliminate fragmented property operations and accounting silos, lower the cost per square foot of property assets under management, and improve cash flow. With global resources and experience in most real estate technology platforms, we help even the most complex organizations turn data into profit. By integrating advanced technology into your operations, we help ensure your real estate investments are both efficient and profitable.
We help you navigate the dynamic commercial real estate landscape with essential support in project finance and consulting, including complex financial modeling, turnkey compliance, and leveraging tax credits like Opportunity Zones and New Markets Tax Credits. Our comprehensive services help ensure the economic viability and strategic success of your investments, fostering community development and maximizing returns on your projects.
Don’t pay more — or sell for less — than your property is worth. Through our proprietary financial modeling, expert valuations and appraisals, preparation of financial statements, and support with acquisition negotiations, your position will be clear.
Optimizing the performance of real estate portfolios is complex. Market volatility, changing tax legislation, and fragmented systems are among the many factors that inhibit profit acceleration. Traditional solutions require working with multiple vendors. There is a better way - REalign.
Test
- States
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ALABAMAOver $250,000 in retail sales and enumerated activity per Ala. Code § 40-23-68 Ala. Admin. Code r. 810-6-2-.90.03(1); See also, ADOR Announces Sales and Use Tax Guidance for Online Sellers, issued by the Alabama Dept. of Revenue (7/3/2018)..
Alabama Administrative Code r. 810-602.90.03(1)
Enforcement Date: 10/01/2018 -
ALASKAAlaska does not assess a state sales and use tax.
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ARIZONAGross income derived from sales exceeding $200,000 in 2019, $150,000 in calendar year 2020; and $100,000 in calendar year 2021 and subsequent years. Ch 273 (H.B. 2757), Laws 2019, effective 08/27/2019, and applicable as noted; News Release, Arizona Dept of Revenue, 05/31/2019.
Enforcement Date: 10/01/2019 -
ARKANSAS$100,000 in aggregate sales or 200 transactions in the current or prior calendar year
Act 822 (S.B. 576), Laws 2019
Enforcement Date: 07/01/2019 -
CALIFORNIAOver $500,000 gross sales during the current or prior calendar year. Additionally, all retailers (in and outside California) are required to collect and pay to the CDTFA district use tax on all sales made for delivery in any district that imposes a district use tax if in the preceding or current calendar year the total combined sales of TPP in the state or for delivery in the state exceed $500,000.
A.B. No. 147; L.2019, A147 (c.5); Cal. Rev. & Tax Code 7262
Enforcement Date: 04/01/2019 -
COLORADOOver $100,000 in gross revenue during the current or prior calendar year; or 200 or more separate transactions during the current or prior calendar year.
Colo. Code Regs. 39-26-204.2(1)(b)(I)(II)
Enforcement Date: 12/01/2018 with a grace period until 06/01/2019 -
CONNECTICUTEffective 07/01/2019, out-of-state retailers that make retail sales of tangible personal property or services from outside Connecticut to a destination within Connecticut must collect and remit sales or use tax if they made at least 200 Connecticut sales during the preceding 12-month period ending Sept. 30; and their gross receipts are $100,000 or more during that period.
Formerly, such retailers were obligated to collect and remit sales tax if they made at least 200 Connecticut sales during the 12-month period and their gross receipts were $250,000 or more during that period.
The newly enacted provision lowers the threshold to 200 transactions and $100,000 in gross receipts during the 12-month period; expands it to apply to out-of-state retailers making retails sales of services, as opposed to just tangible personal property; and eliminates the condition that such retailers be regularly or systematically soliciting sales in Connecticut. Conn. Gen. Stat. §12-407; L. 2019, H7424 (P.A. 19-117)
Enforcement Date: 07/01/2019 -
DELAWAREDelaware does not assess a state sales and use tax.
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DISTRICT OF COLUMBIAOver $100,000 of gross receipts from retail sales during the current or prior calendar year or more than 200 separate retail sales transactions during the current or prior calendar year D.C ACT 22-556 (12/31/2018); OTR Notice 2019-02 (01/02/2019)
Enforcement Date: 01/01/2019 -
FLORIDAGross sales in excess of $100,000 during the prior calendar year. SB 50; Fla. Stat. §§ 212.02, 212.05, 212.054, 212.0596
Enforcement Date: 07/01/2021 -
GEORGIACurrent Rule: Over $100,00 in gross revenue in the previous or current calendar year or 200 or more separate retail transactions in the previous or current calendar year. H.B. 182
Prior Rule: Over $250,000 in gross revenue in the previous or current calendar year or 200 or more separate retail transactions in the previous or current calendar year. If the remote seller chooses not to collect and remit sales tax, on 1/1/2019, the seller must notify each potential purchaser immediately prior to the completion of each retail sale transaction that sales/use tax may be due. On/before 1/31/2020, and each year thereafter, the seller must send a sales/use tax statement to the purchaser who completed one or more retail sales totaling $500 or more in aggregate during the prior calendar year; and also on/before 1/31/2020, must file a copy of the same notice with the state.
GA Code Ann. §§ 48-8-2(M.1, M.2); 48-8-30(c.1, c.2); GA DOR Policy Bulletin SUT-2018-07 (10/1/2018)
The Notice and Reporting rule cited above was repealed effectie 4/28/2019.
Current Rule Enforcement Date: 01/01/2020
Prior Rule Enforcement Date: 01/01/2019 -
HAWAIIOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Hawaii State Legislature Act 41 (S.B. 2514)
Enforcement Date: 07/01/2018 -
IDAHOOver $100,000 in gross receipts in the current or prior calendar year.
L. 2019, H259.
Enforcement Date: 06/01/2019 -
ILLINOIS$100,000 or more gross sales or 200 or more transactions in four (4) prior quarters.
Illinois Public Act 100-0587
Enforcement Date: 10/01/2018 -
INDIANAOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Indiana Code § 6-2.5-2-1(c)
Enforcement Date: 10/01/2018 -
IOWAOver $100,000 gross sales in the current or prior calendar year.
Iowa Code 423.14A(3)(d)(1)
Enforcement Date: 07/01/2019
From 01/01/2019 - 06/30/2019, over $100,000 gross sales in the during current or prior calendar year or 200 separate transactions during the current or prior calendar year.
Enforcement Date: 07/01/2019 -
KANSASEffective 7/1/2021, remote sellers will be required to register to collect/remit sales tax if, in the current or immediately preceding calendar year, the remote seller has more than $100,000 of cumulative gross receipts from sales to Kansas customers.
S.B. 50, Laws 2021
From 8/1/2019 - 6/30/2021, Kansas imposed its sales and use tax collection requirements to the fullest extent permitted by law. Specifically, …, K.S.A. § 79-3702(h)(1)(F) provides that a retailer doing business in Kansas means: (F) any retailer who has any other contact with [Kansas] that would allow [Kansas] to require the retailer to collect and remit tax under the provisions of the constitution of the laws of the United States.
Kansas can, and does, require online and other remote sellers with no physical presence in Kansas to collect and remit the applicable sales or use tax on sales delivered into Kansas. Accordingly, a remote seller must register with Kansas and obtain a sales and/or use tax account number.
Kansas Notice 19-14 (8/1/2019)
Current Rule Enforcement Date: 07/01/2021
Prior Rule Enforcement Date: 08/01/2019 -
KENTUCKYOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Kentucky Department of Revenue HB 487
Enforcement Date: 10/01/2018 -
LOUISIANAOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Louisiana Remote Sellers Information Bulletin 18-001 (08/10/2018)
Enforcement Date: 01/01/2019 -
MAINEOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Maine Revised Statutes Annotated § 1951-B
Enforcement Date: 07/01/2018 -
MARYLANDOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Maryland Code Regulations § 03.06.01.33x
Enforcement Date: 10/01/2018 -
MASSACHUSETTSOver $100,000 gross sales in the current or prior calendar year. (Enacted 8/1/2019 - H. 4000, Laws 2019, effective October 1, 2019)
From 10/1/2017 - 9/30/2019 the rule was over $500,000 in gross sales during the preceding calendar year from transactions completed over the internet and made sales resulting in a delivery into Massachusetts in 100 or more transactions. 830 CMR 64H.1.7(3)
Enforcement Date: 10/01/2019 -
MICHIGANOver $100,000 gross sales in the previous calendar year or more than 200 transactions in the previous calendar year.
Michigan Revenue Administrative Bulletin 2018-16 (08/01/2018)
Enforcement Date: 10/01/2018 -
MINNESOTAOver $100,000 in retail sales in 10 or more transactions or 100 or more retail transactions.
MN Dept. of Rev. News Release (07/25/2018)
Enforcement Date: 10/01/2018
Effective after 09/30/2019: Retail sales totalling more than $100,000 during the prior 12-month period; or 200 or more retail sales during the prior 12-month period. Ch. 6 (H.F. 5), First Special Session, Laws 2019, effective 05/30/2019, except as noted
Enforcement Date: 10/01/2019 -
MISSISSIPPIOver $250,000 in gross sales for the last 12-months and exploitation of the Mississippi market.
Mississippi Code R. § 35.IV.3.09.100, .101
Enforcement Date: 09/01/2018 -
MISSOURI$100,000 in cumulative gross receipts in a twelve-month period.
Missouri SB 153 & 97.
Enforcement Date: 01/01/2023 -
MONTANAMontana does not assess a state sales and use tax.
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NEBRASKAOver $100,000 in sales or 200 or more retail transactions annually.
Nebraska DOR: Notice for Remote Sellers and Marketplace Facilitators.
Enforcement Date: 04/01/2019 -
NEVADAOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
LCB File No R189-18
Enforcement Date: 10/01/2018 -
NEW HAMPSHIRENew Hampshire does not assess a state sales and use tax.
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NEW JERSEYOver $100,000 gross sales during the current or prior calendar year or 200 or more transactions during the current or prior calendar year.
Notice, Sales and Use Tax Information for Remote Sellers, NJ Division of Taxation
Enforcement Date: 11/01/2018 -
NEW MEXICOAt least $100,000 in gross sales during the prior calendar year.
2019 NM H 6, Adopted
Enforcement Date: 07/01/2019 -
NEW YORKCurrent Rule: Greater than $500,000 in sales of tangible personal property delivered in state and conducted more than 100 sales of tangible personal property delivered in state in the immediately preceding four sales tax quarters. The sales tax quarters are Mar. 1 through May 31, Jun. 1 through Aug. 31, Sept. 1 through Nov. 30, and Dec. 1 through Feb. 28/29. N.Y. Tax Law §§ 1101(b)(8)(i)(E), 1101(b)(8)(iv); see also, New York Department of Taxation and Finance Notice N-19-1 (1/15/2019)
Prior Rule: Prior to 7/1/2019 the dollar threshold was $300,000 and more than 100 sales of tangible personal property delivered in state in the immediately preceding four (4) sales tax quarters.
Prior Rule Enforcement Date: 06/21/2018
Revised Rule Enforcement Date: 07/01/2019 -
NORTH CAROLINAOver $100,000 gross sales in the previous or current calendar year or 200 or more transactions in the previous or current calendar year.
Ch. 6 (S.B. 56), Laws 2019, effective 03/20/2019
Enforcement Date: 11/01/2018 -
NORTH DAKOTAOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
North Dakota Century Code §§ 57-39.2-02.2; 57-40.2-02.3
Enforcement Date: 10/01/2018 -
OHIOOver $100,000 gross sales in the previous or current calendar year or 200 or more transactions in the previous or current calendar year. Ohio Rev. Code Ann. § 5741.01(S) and 5741.17(c)
From 1/1/2018 - 7/31/2019, the rule was over $500,000 gross sales during the current or preceding calendar year through in-state software. Ohio Rev. Code Ann. § 5741.01
Enforcement Date: 08/01/2019 -
OKLAHOMAEffective 11/1/2019, the threshold increases to $100,000 in gross sales during the preceding or current calendar year and a remote seller are no longer allowed to make an election to comply with notice reporting requirements.
L. 2019, S513
Prior Rule: Over $10,000 in aggregate OK sales in prior 12 month calendar period (collect or comply with notice and reporting requirements)
State law HB1019xx; Remote Seller Info & FAQs
Prior Rule Enforcement Date: 07/01/2018
Revised Rule Enforcement Date: 11/01/2019 -
OREGONOregon does not assess a state sales and use tax.
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PENNSYLVANIA1. Elect to register or comply with notice & reporting requirements: A remote seller, marketplace facilitator or a referrer that had aggregate PA taxable sales of at least $10,000, but less than $100,000 during the previous 12-month period. (Election must be made by 03/01/2018 and each subsequent June 1st beginning 06/01/2019). Pennsylvania Sales & Use Tax Bulletin 2019-01 (Issued 01/08/2019; revised 01/11/2019)
Enforcement Date: 04/01/2018
2. Must register to collect sales tax: A remote seller, marketplace facilitator or a referrer that had aggregate PA taxable sales greater than $100,000 over the previous 12-month period. Pennsylvania Sales & Use Tax Bulletin 2019-01 (Issued 01/08/2019; revised 01/11/2019; effective 07/01/2019)
Enforcement Date: 07/01/2019
Notice and reporting requirements were not necessarily repealed; however if a remote seller now meets economic nexus in PA, the Act 43 notice provisions are no longer an option and thus, a remote seller MUST register and begin collecting sales/use tax. -
RHODE ISLANDGross revenue from the sale of tangible personal property, prewritten computer software delivered electronically or by load and leave, vendor-hosted prewritten computer software, and/or has taxable service delivered into Rhode Island equal to or exceeding $100,000; or has sold tangible personal property, prewritten computer software delivered electronically or by load and leave, vendor-hosted prewritten computer software, and/or taxable services for delivery into Rhode Island in 200 or more separate transactions. R.I. Gen. Laws §§ 44-18.2-2(4), 44-18.2-3; See also, L. 2019, S251; Rhode Island Advisory No. 2019-11, (5/24/2019) Rhode Island Advisory No. 0217-09 (4/4/2017)
Enforcement Date: 01/01/2019
Note: Rhode Island had a prior notice reporting rule that was enforcable on 8/1/2017. This rule was repealed in favor of the economic nexus rule stated above.
Prior Rule Enforcement Date: 08/17/2017
Revised Rule Enforcement Date: 07/01/2019 -
SOUTH CAROLINAOver $100,000 gross sales in the current or prior calendar year.
Revenue Ruling #18-14, South Carolina Department of Revenue (09/18/2018)
Enforcement Date: 11/01/2018 -
SOUTH DAKOTAOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
South Dakota Codified Laws §10-64-2
Enforcement Date: 11/01/2018 -
TENNESSEEOver $500,000 in gross sales and during the previous 12 month period and engage in the regular or systematic solicitation of consumers in Tennessee through any means. Remote sellers who meet the sales threshold as of 7/31/2019 must register and begin collecting sales/use tax by 10/1/2019. If a remote seller meets the $500,000 threshold after 7/31/2019, the remote seller is required to register and begin collecting sales/use tax on the first day of the third month in which it meets the threshold.
L.2019,H667; Tenn. Comp. R. & Regs. § 1320-05-01-.129(2); See also, Tennessee Sales Tax Notice No. 19-04 (6/1/2019)
The dollar threshold above is reduced to $100,000 effective 10/1/2020.; all else remains the same.
Tenn. Code Ann. § 67-6-543; (Ch. 759 (S.B. 2932), Laws 2020)
Prior Rule Enforcement Date: 10/01/2019
New Rule Enforcement Date: 10/01/2020 -
TEXAS$500,000 or greater of gross revenue in the preceding 12 calendar months. The initial 12 calendar months for determining a remote seller's total Texas revenue will be 07/1/2018 - 06/30/2019. If a remote seller's Texas revenue during this period exceeds $500,000 the seller must obtain a permit by 10/01/2019 and begin collecting use tax no later than 10/01/2019.
Adopted Rules - 43 TexReg 8133 (12/14/2018); 34 TAC 3.286
Enforcement Date: 10/01/2019 -
UTAHOver $100,000 in gross sales in either the previous or current calendar year or 200 or more separate transactions in the previous or current calendar year.
Utah Code Annotated §59-12-107(2)(c)(ii)
Enforcement Date: 01/01/2019 -
VERMONT$100,000 or more gross sales or 200 or more transactions during any 12-month period preceding the monthly period.
Vermont Statutes Annotated § 9701(9)(f)
Enforcement Date: 07/01/2018 -
VIRGINIAOver $100,000 in gross sales in either the previous or current calendar year or 200 or more separate transactions in the previous or current calendar year.
L. 2018, H1722 (c. 815), effective 07/01/2019; L. 2018, S1083 (c. 816) effective 07/01/2019; See also, Guidelines for Remote Sellers and Marketplace Facilitators, Virginia Department of Taxation, May 2019.
Enforcement Date: 07/01/2019 -
WASHINGTONEffective from 10/01/2018 through 12/31/2019 sellers are required to collect and remit sales tax if they have, in the current or immediately preceding calendar year, more than $100,000 of cumulative gross receipts from Washington, 200 or more separate transactions for the delivery of products into Washington or physical presence under Wash. Rev. Code § 82.04.067.
However, sellers subject to a sales and use tax collection requirement only because of the 200 transaction threshold are relieved of their collection obligation, effective 03/14/2019.
Effective 01/01/2020, sellers with greater than $100,000 of cumulative gross receipts; or subject to the limitation in RCW 82.32.531, physical presence in the state, which need only be demonstrably more than a slightest presence. Wash. Rev. Code § 82.04.067; RCW 82.32.531; News Release, Washington Department of Revenue, 03/18/2019
Enforcement Date: 10/01/2018 -
WEST VIRGINIADuring the previous tax year either delivered more than $100,000 of goods or services into West Virginia; or engaged in 200 or more separate transactions for the delivery of goods and services into West Virginia.
Administrative Notice 2018-18, West Virginia State Tax Department (10/01/2018)
Enforcement Date: 01/01/2019 -
WISCONSINOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Wisconsin Statute § 11.97(4)
Enforcement Date: 10/01/2018 -
WYOMINGOver $100,000 gross sales in the current or prior calendar year or 200 or more transactions in the current or prior calendar year.
Wyoming Statutes Annotated § 39-15-501
Enforcement Date: 02/01/2019
