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In the sales tax world, “registrations” can take on multiple meanings. Generally speaking, sales tax registrations refer to the authorization to collect sales tax in a particular jurisdiction. 


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This type of registration occurs at the Department of Revenue or similar agency – sometimes with a local jurisdiction.  Once a valid application has been submitted and the applicable fee or bond paid, the jurisdiction will issue a sales tax license.

In the past when paper-based applications were the norm, a business could complete and mail the application along with their fee or bond to the Department of Revenue.  Many of these applications would also ask for the Secretary of State (SOS) identification number.  With the paper-based application, a business could leave this line blank and in most situations a sales tax license would be issued without a question.

However, now that the applications have been moved online, most of the states require a SOS identification number before the application can be submitted. 

Thus, a second level of registration is required – this one with the Secretary of State.  The SOS grants permission to conduct business in the state. 

As part of the SOS application process, a business must provide the address of their “registered agent” in the state.  What is this? 

A registered agent is someone (a person or company) that receives legal correspondence within the state and forwards this correspondence to the business. 

Essentially, the state needs to know where to send information in the event of a lawsuit.  This doesn’t have to be a separate company that acts as the registered agent.  If the business has an office in the state, then that location can be used.

That would end the process for a business selling tangible personal property and/or services. 

But what happens when a business provides telecommunications services such as VoIP, wireless communication, broadband connectivity, etc.?

 In this situation there are additional registration requirements.  A business would need to determine in which states their particular telecommunications service is subject to regulation.  If the telecommunications service is regulated, then the business would also need to register with the PUC / PSC – Public Utility or Public Service Commission.  Furthermore, there would be a Federal registration obligation with the FCC.

In summary, if selling TPP and providing services, the following are required:

  • Registration with the Department of Revenue which issues the sales tax license
  • Registration with the Secretary of State that grants the right to conduct business in the state
  • Registered Agent to receive legal correspondence

If providing telecommunications services:

  • Registration with the Department of Revenue which issues the sales tax license
  • Registration with the Secretary of State that grants the right to conduct business in the state
  • Registered Agent to receive legal correspondence
  • Registration with the PUC / PSC if the telecommunications service is regulated in the particular state where service is provided
  • Registration with the FCC if the telecommunications service is regulated

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Brian Greer

Written by Brian Greer