When must a Louisiana seller report sales tax on season tickets purchased through installment payments?

Plain-English summary

Louisiana treated an admission as sold on the earliest of three dates: full payment, issuance of the ticket or other evidence of admission, or the customer's actual admission to the event. That earliest event determined the month in which the seller reported state sales tax.

For season tickets paid in installments, the seller generally reported the sale in the month of the final installment—provided no ticket was issued and no admission occurred before then.

Tickets issued before final payment

If the seller issued tickets before receiving the final installment, the sale became reportable in the ticket-issuance month. If the customer was admitted before both ticket issuance and final payment, the admission month controlled.

The dates of the future games did not postpone reporting once the advance tickets had been fully paid for or issued.

Door and gate sales

When no ticket was issued and the customer paid at the door or gate, the seller reported the tax for the month in which the event was held.

Common questions

Q: Was tax due as each installment was received?

A: Not under the stated facts. The seller reported the ticket sale in the final-installment month unless tickets were issued or admission was provided earlier.

Q: Did the game date control for advance season tickets?

A: No. Full payment or ticket issuance could make the sale reportable before the game occurred.

Q: What if tickets were delivered before the buyer finished paying?

A: The ticket-issuance month controlled unless the customer had already been admitted even earlier.

Q: What service was being taxed?

A: La. R.S. 47:301(14)(b) treated admissions to athletic entertainment other than school, college, and university events as taxable services.

Citations and references

• La. R.S. 47:302, 47:321, and 47:331 — sales tax on taxable services
• Louisiana Tourism Promotion District sales and use tax ordinance
• La. R.S. 47:301(14)(b) — sale of admissions to amusement, qualifying athletic entertainment, and recreational events
• LAC 61:III.101 — Private Letter Ruling authority and reliance limitations

Source

• Landing page: Louisiana Department of Revenue Policies
• Original PDF: LA PLR 01-003

Original ruling text

STATE OF LOUISIANA

DEPARTMENT OF REVENUE
M. J. "MIKE" FOSTER, JR.

CYNTHIA BRIDGES

Governor

Secretary

Private Letter Ruling No. 01-003
Redacted Version
December 12, 2001
The Department of Revenue was asked to issue a private letter in answer to the following question:
When is a seller required to report state sales tax on sales of season tickets for the
games of a professional athletic team in cases where the tickets are paid for in
installments? Is the dealer required to report the sales tax when each installment
payment is received, when the final payment is received, when the tickets for
future games are sent to the purchasers, or when the games are played?
The Department answered as follows:
The Law

Louisiana Revised Statutes Title 47, Sections 302, 321, 331, and the sales and use tax ordinance of
the Louisiana Tourism Promotion District levy tax upon all sales of those services that are defined in
the sales tax law. Among the taxable services is the one defined by La. R.S. 47:301(14)(b), which
provides in pertinent part as follows:
“(14) ‘Sales of services’ means and includes the following:
*

*

*

(b) (i) The sale of admissions to places of amusement, to athletic entertainment
other than that of schools, colleges, and universities, and recreational events, . . .”
Ruling

The above statute levies the tax on the “sale of admissions”. For purposes of reporting sales taxable
transactions, admissions are considered sold on the date that full payment for admissions is
collected; the date the customer receives a ticket evidencing his/her right of admission; or the date
that the customer is actually admitted to the amusement, athletic, or recreational event, whichever
date is earliest. In the case where advance event tickets or other evidence of the right of admission
are furnished to customers for events on specific future dates, the state sales tax will be reportable on
sales tax returns for the month in which the tickets are fully paid for, or the month that the tickets are
issued to customers, whichever dates are earlier, regardless of the date of the events. In cases where
tickets are not issued, but payment is made at the door or gate to the taxable event, the sales tax will
be reportable on the sales tax return for the month that the event is held.

Post Office Box 201 Baton Rouge 70821-0201
Telephone 225-925-7537 225-925-7533 (TDD)
An Equal Opportunity Employer

Dealers who accept payments for tickets on an installment basis are required to report those ticket
sales on their state sales tax returns for the months that final installment payments are made,
provided that tickets are not issued to or admissions provided to customers before they make their
final installment payments. If tickets are issued to or admissions are provided to customers before
the final installment payments are made, ticket sales are reportable on dealers’ sales tax returns for
the month that tickets are issued or admissions provided, whichever month is earlier.
Sincerely,

Cynthia Bridges
Secretary
By:

Raymond E. Tangney
Senior Policy Consultant
Policy Services Division
(225) 219-2780

This correspondence constitutes a private letter ruling (PLR) by the Louisiana Department of Revenue, as provided for by section 61:III.101 of the
Louisiana Administrative Code. A PLR provides guidance to a specific taxpayer at the taxpayer's request. It is a written statement that applies
principles of law to a specific set of facts or a particular tax situation. A PLR does not have the force and effect of law, and is not binding on the
person who requested it or on any other taxpayer. This PLR is binding on the department only as to the taxpayer to whom it is addressed, and
only if the facts presented were truthful and complete and the transaction was carried out as proposed. It continues as authority for the
department's position unless a subsequent declaratory ruling, rule, court case, or statute supersedes it.