Ezel / Tax Rulings / TX
TX 8906L0940D08 Sales and/or Use Tax (State,Local,MTA) 1989-06-26

How did Texas source local tax on cable-TV service bills around the September 1, 1987 law change?

Short answer: Bills for service beginning before September 1, 1987 used the former Rule 3.313 allocation; later service was sourced where delivered.

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This page answers the general question as of 1989. Ezel answers yours, under current Texas tax law, with citations.

Currency note: this ruling is from 1989
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is NOT a taxpayer-specific letter ruling. It is an internal Texas Comptroller of Public Accounts Tax Correspondence memorandum to audit staff, published on the State Tax Automated Research (STAR) system for reference. It does not carry letter-ruling reliance protection under 34 Tex. Admin. Code Rules 3.1 and 3.10 and is included only as a historical record of 1989 internal guidance about a 1987 sourcing change. It may no longer reflect current law or Comptroller policy. This summary is informational only and is not legal or tax advice. Consult a licensed Texas tax professional about your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page) is the authoritative source for any reliance.

Plain-English summary

This internal memorandum told audit staff how to allocate local taxes on cable-TV services after a sourcing change effective September 1, 1987.

Bills for service that began before September 1 were allocated under the December 12, 1984 version of Rule 3.313. Bills for service beginning on or after September 1 were allocated based on where the service was delivered to the customer.

The memo said a copy of the bill making the change was attached, but that attachment is not part of the STAR text preserved here.

Common questions

What controlled the transition treatment? The date the billed service began.

How was service beginning before September 1, 1987 sourced? Under the allocation reflected in the December 12, 1984 version of Rule 3.313.

How was later service sourced? Based on where the service was delivered to the customer.

Source

Original ruling text

COMPTROLLER OF PUBLIC ACCOUNTS
STATE OF TEXAS

June 26, 1989

To: Sheila Natho, Dallas West Audit

From: Sandi Skaggs, Tax Correspondence

Subject: Local Taxes on Cable TV Services

As we discussed last week, the allocation of local taxes for cable
television services was changed effective September 1, 1987.

This means for all bills for services which began before September
1, the allocation is done as reflected in the December 12, 1984
version of Rule 3.313. On the other hand, for all bills for ser-
vice which began on September 1 or after, the local taxes are al-
located based on where the service is delivered to the customer.

For your reference, attached is a copy of the bill making this
change.

If you have any more problems in this area, please let me know.

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