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.
No Florida rulings match these filters
Try a different search term or clear the filters.
Were a city's country-club direct purchases exempt, and were a nonprofit manager's loan repayments taxable commercial rent?
The city's purchases were exempt only when made strictly through the stated direct-purchase procedures. The nonprofit manager's loan repayments were not taxable rent because the agreement created a co…
Were fabricated variable message signs installed for FDOT tangible personal property or real-property improvements, and who owed tax?
They were real-property improvements under the attachment-focused law discussed in the ruling. The contractor, not FDOT, owed tax on materials and manufactured cost and did not collect sales tax from …
Could a city buy public-library construction materials tax-free under its direct-purchase procedures?
Yes, if the controlling documents were fully executed and the city remained the purchaser in substance and form. The city had to issue purchase orders with its exemption number, receive vendor invoice…
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…
Could a public authority buy bridge-and-roadway materials tax-free through direct purchases?
Yes, based on the submitted contract section. The authority had to issue purchase orders and exemption documents, receive invoices, pay vendors directly, take title and liability at delivery, and bear…
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…
Did a county's airport public-works agreement make the county the tax-exempt purchaser of construction materials?
No. The agreement did not clearly include any of six required protections: county purchase orders with its exemption number, county title and liability at job-site delivery, direct vendor invoices, di…
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 generator direct-purchase arrangement qualify for exemption when the contractor kept title and risk of loss until final acceptance?
No. Direct city purchase orders, invoices, payment, and insurance were not enough because the contract left title and risk of loss with the contractor until city acceptance. The city could qualify fut…
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 qualify seaport capital-improvement materials for Florida's government sales-tax exemption?
Yes. The county issued purchase orders with its exemption number, received vendor invoices, paid directly, took title and liability at job-site delivery, assumed risk of loss, and carried insurance. T…
Did county-furnished-material procedures qualify airport rental-car-facility construction materials for Florida's government exemption?
Yes, on the submitted contract section and stated assumptions. The county issued approved purchase orders with its exemption number, received invoices, paid vendors directly, took title and liability …
Did a city's direct-purchase procedures make construction materials for its utilities expansion project exempt from Florida sales tax?
Yes, except for contractor or subcontractor off-site fabrication. The city qualified as the purchaser when it issued documented purchase orders, took title and liability at delivery, was invoiced and …
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 a Florida county buy airport access-road materials tax-free while its design-build contractor handled procurement tasks?
Yes, if the controlling documents and actual purchases followed the stated safeguards. The county had to issue and approve its own purchase orders, give vendors its exemption certificate, receive invo…
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…
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…
Could a Florida county buy materials for airport-terminal renovations tax exempt while its contractor handled requisitions and delivery?
Yes, if the county was the purchaser in substance: it had to use its own purchase orders and exemption number, receive direct invoices, pay vendors directly, take title and liability at delivery, and …
Could a Florida county buy airport-construction materials tax exempt while its contractor handled requisitions and delivery?
Yes, for purchases made under the described amendment on or after December 7, 1999, if the county—not the contractor—used its purchase orders, gave vendors its exemption certificate, took title and li…
Could a Florida school district buy construction materials tax exempt while contractors managed three school projects?
Yes, if the district was the purchaser in substance: it had to issue its own purchase orders and exemption certificate, receive direct invoices, pay vendors directly, take title and liability at deliv…
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…
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 school board buy materials tax-free for school additions under its direct-purchase procedures?
Yes, if the board directly ordered and paid vendors, took title and liability at delivery, and bore the risk of loss before the materials were installed.
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 county facilities manager buy janitorial services for resale and provide repair materials tax-free?
The manager could not buy janitorial services for resale because it was not primarily a janitorial seller or registered dealer. County-paid tangible-property repairs could be exempt with a valid certi…
Could a Florida school district buy construction materials tax-free through a direct-purchase program while a construction manager built the schools?
Yes. The district was the exempt purchaser because it issued purchase orders, provided its exemption certificate, received vendor invoices, paid vendors directly, took title, and bore the insured risk…
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…
Browse Florida rulings by topic
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.