Florida State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Florida, with full citations and the original source on every page.
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Could the public authority buy bridge-construction materials directly without Florida sales tax?
Yes. The authority's direct material purchases were exempt when it issued the purchase orders, gave vendors its exemption certificate, was invoiced and paid directly, took title, and bore the risk of …
Which public-works materials could the owner buy tax-free, and when did the contractor owe use tax?
Owner-direct purchases could be exempt when the owner ordered, paid vendors, took title, and bore the risk of loss. But the owner's exemption did not cover materials the contractor fabricated in its o…
Could a county buy office-building materials tax-free under its owner-direct purchase procedure?
Yes. The county's procedure qualified when it issued purchase orders and exemption documents, received vendor invoices, paid vendors directly, took title and liability at delivery, and bore the insure…
Could a county buy courthouse-construction materials tax-free under its owner-direct purchase procedure?
Yes. The county's procedure qualified when it issued purchase orders and exemption documents, received vendor invoices, paid vendors directly, took title and liability at delivery, and bore the insure…
Did a city's direct-purchase procedure exempt construction materials for a public library from Florida sales tax?
Yes. The city was the purchaser in substance and form because it issued purchase orders with its exemption number, was invoiced and paid vendors directly, took title and liability at job-site delivery…
Could a city use a construction-management direct-purchase program to buy stadium materials tax free?
Yes, conditionally. The city would select materials, issue purchase orders in its name with its exemption number, pay vendors directly, take title on receipt, and insure the materials as sole loss ben…
Could a school board buy materials tax exempt for additions at three elementary schools under its proposed direct-purchase procedures?
Yes. The procedures made the school board the purchaser because it issued purchase orders with its exemption number, received direct invoices, paid vendors directly, took title and liability at job-si…
Could a school board buy materials tax exempt for a junior-high media-center project under its proposed direct-purchase procedures?
Yes. The procedures made the school board the purchaser because it issued purchase orders with its exemption number, received direct invoices, paid vendors directly, took title and liability at job-si…
Did a state university's proposed direct-purchase program qualify construction materials for Florida's government sales-tax exemption?
Yes, if the controlling documents made the university the buyer. It had to issue purchase orders with its exemption number, receive invoices, pay vendors directly, take title and liability at delivery…
Did a city's direct-purchase procedures qualify police-station construction materials for Florida's government sales-tax exemption?
Yes. The city issued purchase orders with its exemption number, received direct invoices, paid vendors directly, took title and liability at job-site delivery, and bore insured risk of loss. Those doc…
Did a county's direct-purchase procedures make convention-center construction materials exempt from Florida sales tax?
Yes, if the county remained the purchaser in substance and form. It had to issue purchase orders and its exemption certificate, receive direct vendor invoices, pay vendors directly, take title and lia…
Could government and qualifying nonprofit owners directly buy project materials tax-free?
Yes. Government and qualifying nonprofit owners could buy project materials tax-free when they issued purchase orders, paid vendors directly, took title and liability, and bore insured risk of loss. C…
Could a Florida school board directly buy school-construction materials without sales tax?
Yes. The school board's material purchases were exempt when it issued its own purchase orders with its exemption number, was invoiced and paid directly, held title and liability, and bore insured risk…
Could a Florida city use a direct-purchase program to buy public-works materials tax-free?
Yes. The city's direct purchases could be exempt when its contract preserved the city as the real purchaser through city purchase orders, direct vendor payment, title, and insured risk of loss. The re…
Could a public authority directly buy wastewater-project materials without sales tax?
Yes. The authority's direct material purchases were exempt when it issued purchase orders, paid vendors, held title and liability, and bore insured risk of loss under the contract. Contractor-manufact…
Who owed Florida tax when an out-of-state drop shipper delivered goods to a Florida buyer?
For common-carrier delivery from outside Florida, the drop shipper's sale to the unregistered out-of-state customer was not a Florida sale, so the shipper did not collect tax; the Florida buyer genera…
Could a governmental unit buy wastewater-project materials tax-free through direct purchases?
Yes, if the governmental unit was the purchaser in substance and form. It had to issue purchase orders with its exemption number, receive direct invoices, pay vendors directly, take title and liabilit…
Can a Florida community college buy materials for a public construction project tax-free through a direct-purchase program?
Yes, under the procedures reviewed. The college was the actual purchaser because it issued purchase orders, was invoiced and paid vendors directly, took title and liability at delivery, carried the ri…
Could a Florida county buy performing-arts-center construction materials tax-free through direct purchasing?
Yes, under the amended procedures reviewed. The county issued purchase orders, received invoices and paid vendors directly, took title and liability at delivery, was insured against loss, and provided…
Who owed Florida tax on materials used in three types of air-conditioning repair contracts?
The contractor did. For time-and-material, lump-sum, and not-to-exceed repairs, the contractor was the ultimate consumer because materials were not fully identified and priced before work began. It pa…
Can a Florida governmental entity buy construction materials tax-free for a public works project using a contractor's direct-purchase procedures?
Yes, if the government is the real purchaser: it must order, take title to, pay vendors for, and bear the risk of loss on the materials before they are incorporated into the project.
Could a Florida city buy construction materials tax-free for a fire-station project under a direct-purchase contract addendum?
Yes, after proper execution of the addendum, if the city ordered and paid vendors directly, took title and liability at delivery, and bore the risk of loss before installation.
Could a Florida school district buy construction materials tax-free under its school-building direct-purchase program?
Yes, if the district directly ordered and paid vendors, took title and liability at delivery, and bore the risk of loss before the materials were incorporated into the schools.
Could a Florida county buy courthouse construction materials tax-free through a direct-purchase procedure?
Yes. The purchases were exempt when the county—not the contractor—issued purchase orders, received vendor invoices, paid directly, took title and liability at delivery, assumed insured risk of loss, a…
Could a public port agency buy construction materials tax-free for a terminal renovation through a direct-purchase procedure?
Yes. The agency's direct purchases were exempt because it issued purchase orders, received vendor invoices, paid vendors, took title at delivery, and bore the risk of loss through insurance before ins…
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These are official tax letter rulings and advisory opinions issued by Florida's revenue authority in response to questions from specific taxpayers about how the tax law applies to their facts. A ruling is binding on the department only for the taxpayer who requested it and cannot be relied on by anyone else, but it is strong evidence of how the state reads the law. Every ruling above has a plain-English question and short answer, plus a link to the full original source.