HLS 17RS-47 ORIGINAL
2017 Regular Session
HOUSE BILL NO. 628
BY REPRESENTATIVE JONES
TAX: Imposes the Commercial Activity Tax
1 AN ACT
2To enact Part II-B of Chapter 2 of Subtitle II of Title 47 of the Louisiana Revised Statutes
3 of 1950, comprised of R.S. 47:288.1 through 288.7, relative to the commercial
4 activity tax; to provide for the rate and calculation of the tax; to provide for
5 definitions; to provide for exemptions; to provide for requirements and limitations;
6 to authorize the promulgation of rules and regulations; to require the filing of
7 consolidated returns under certain circumstances; to provide for administration of the
8 tax; to provide for an effective date; and to provide for related matters.
9Be it enacted by the Legislature of Louisiana:
10 Section 1. Part II-B of Chapter 2 of Subtitle II of Title 47 of the Louisiana Revised
11Statutes of 1950, comprised of R.S. 47:288.1 through 288.7, is hereby enacted to read as
12follows:
13 PART II-B. LOUISIANA COMMERCIAL ACTIVITY TAX
14 §288.1. Short title
15 This Act shall be known as and may be cited as the "Louisiana Commercial
16 Activity Tax Act".
17 §288.2. Imposition of Tax
18 A. Every corporation, partnership, limited liability company, limited liability
19 partnership, limited partnership, estate, trust, or association, whether domestic or
20 foreign, exercising its charter, or qualified to do business or actually doing business
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1 in this state, or owning or using any part or all of its capital, plant, or any other
2 property in this state, subject to compliance with all other provisions of law, shall
3 pay an annual commercial activity tax as provided by R.S. 47:288.4. The tax levied
4 herein is due and payable on any one or all of the following alternative incidents:
5 (1) The qualification to carry on or do business in this state or the actual
6 doing of business within this state. The term "doing business" as used herein shall
7 mean and include each and every act, power, right, privilege, or immunity exercised
8 or enjoyed in this state, as an incident to or by virtue of the powers and privileges
9 acquired by the nature of such organizations, as well as, the buying, selling, or
10 procuring of services or property.
11 (2) The exercising of an organization's charter or the continuance of its
12 charter within this state.
13 (3) The owning or using any part or all of its capital, plant, or other property
14 in this state.
15 B. It is the purpose of this Section to require the payment of this tax to the
16 state of Louisiana by organizations for the right granted by the laws of this state to
17 exist and for the enjoyment, under the protection of the laws of this state, of the
18 powers, rights, privileges, and immunities derived by reason of the organization's
19 form of existence and operation. The tax hereby imposed shall be in addition to all
20 other taxes levied by any other statute.
21 §288.3. Definitions
22 As used in this Part:
23 (1) "Bulk delivery costs" means the cost of delivering the product to the
24 consumer if both of the following apply:
25 (a) The tangible personal property is delivered in bulk and requires
26 specialized equipment that generally precludes commercial shipping.
27 (b) The tangible personal property is taxable under R.S. 47:818.12.
28 (2) "Business of gaming" means a business that is assigned an industry group
29 designation by the United States Census Bureau of Sectors 713210 or 713290
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1 pursuant to the North American Industry Classification System and is licensed under
2 the provisions of Title 27 of the Louisiana Revised Statutes of 1950 to conduct
3 gaming activities or gaming operations.
4 (3) "Business of manufacturing and merchandising" means a business whose
5 gross receipts or gross profits is derived primarily from the manufacture, production,
6 or sale of tangible personal property, whether at wholesale or retail. The term
7 "business of manufacturing or merchandising" shall not include any of the following:
8 (a) A taxpayer subject to the tax imposed pursuant to Chapter 8 of Subtitle
9 II of this Title.
10 (b) Any taxpayer whose income is primarily derived from the production or
11 sale of unrefined oil and gas.
12 (c) Any taxpayer defined as an integrated oil company per the United States
13 Internal Revenue Code 26 U.S.C. 291(b)(4), or integrated oil companies that refine,
14 produce, and have marketing operations, whose income in Louisiana is principally
15 derived from production and sale of unrefined oil and gas, and who also engage in
16 significant marketing of refined petroleum products in Louisiana. Any taxpayer,
17 whose activities during the taxable year do not include any "gross receipts from retail
18 sales of oil or natural gas", or any "refinery activities of oil or natural gas", shall not
19 be considered as an integrated oil company for Louisiana tax purposes,
20 notwithstanding such taxpayer may be a "related party" or a "member of the federal
21 consolidated group" under the United States Internal Revenue Code.
22 (4) "Cost of goods sold" means either of the following:
23 (a) Amounts that are both of the following:
24 (i) Allowable as cost of goods sold pursuant to the United States Internal
25 Revenue Code and any guidelines issued by the Internal Revenue Service relating
26 to cost of goods sold, unless modified by this Section.
27 (ii) Incurred in acquiring or producing the tangible personal property
28 generating the Louisiana gross receipts.
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1 (b) For entities engaged in the business of manufacturing or merchandising,
2 cost of goods sold shall only include costs directly incurred in acquiring or producing
3 the tangible personal property for sale at wholesale or retail. In determining cost of
4 goods sold:
5 (i) Labor costs shall be limited to direct labor costs as defined in Paragraph
6 (5) of this Section.
7 (ii) Bulk delivery costs as defined in Paragraph (1) of this Section may be
8 included.
9 (iii) Costs allowable under Section 263A of the United States Internal
10 Revenue Code may be included only to the extent the costs are incurred in acquiring
11 or producing the tangible product generating the Louisiana gross receipts, provided
12 however that indirect labor costs allowable under Section 263A shall not be
13 included.
14 (c) For entities engaged in a service enterprise in which the gross receipts are
15 primarily attributable to service income and the use of property is not a substantial
16 income-producing factor, no costs shall be included in cost of goods sold.
17 (d) For entities engaged in the business of gaming, costs of goods sold shall
18 only include cash paid out as winnings to patrons.
19 (5) "Direct labor" means labor that is directly involved in the actual process
20 of manufacturing the tangible personal property sold or is an integral part of the
21 manufacturing or merchandising process.
22 (6) "Domestic corporation" means a corporation formed under the laws of
23 this state.
24 (7) "Domestic limited liability company" means an entity that is an
25 unincorporated association having one or more members that is organized and
26 existing under Chapter 22 of Title 12 of the Louisiana Revised Statutes of 1950.
27 (8) "Domestic limited liability partnership" means a limited liability
28 partnership formed under the laws of this state.
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1 (9) "Estate" means a decedent's estate as provided by Civil Code Article 872
2 and a bankruptcy estate as provided by Section 541 of Title 11 of the United States
3 Code.
4 (10) "Foreign corporation" means a corporation formed under the laws of
5 any state other than this state or under the laws of any foreign country.
6 (11) "Foreign limited liability company" means a limited liability company
7 formed under the laws of any state other than this state or under the laws of any
8 foreign country.
9 (12) "Foreign limited liability partnership" means a limited liability
10 partnership formed under the laws of any state other than this state or under the laws
11 of any foreign country.
12 (13) "Gross receipts from all sources" means the sum of the following:
13 (a) Taxable gross receipts from rents and royalties from immovable or
14 corporeal movable property from all sources.
15 (b) Taxable gross receipts from royalties or similar revenue from the use of
16 patents, trademarks, copyrights, secret processes, and other similar intangible rights
17 from all sources.
18 (c) Taxable gross receipts from construction, repair, or other similar services
19 from all sources.
20 (d) Taxable gross receipts from estates, trusts, and partnerships from all
21 sources.
22 (e) Taxable gross receipts from all other items and sources of gross income.
23 (14) "Guidelines issued by the Internal Revenue Service" means regulations,
24 private letter rulings, or any other guidance issued by the Internal Revenue Service
25 that may be relied upon by taxpayers under reliance standards established by the
26 Internal Revenue Service.
27 (15) "Immovable property" means land and all things permanently affixed
28 to the land.
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1 (16) "Louisiana gross profits" means Louisiana gross receipts reduced by
2 cost of goods sold attributable to Louisiana gross receipts. If the amount of cost of
3 goods sold attributable to Louisiana gross receipts is zero, then "Louisiana gross
4 profits" shall mean Louisiana gross receipts.
5 (17) "Louisiana gross receipts" means the sum of the following:
6 (a) Taxable gross receipts from rents and royalties from immovable or
7 corporeal movable property allocable to this state.
8 (b) Taxable gross receipts from royalties or similar revenue from the use of
9 patents, trademarks, copyrights, secret processes, and other similar intangible rights
10 allocable to this state.
11 (c) Taxable gross receipts from construction, repair, or other similar services
12 allocable to this state.
13 (d) Taxable gross receipts from estates, trusts, and partnerships allocable to
14 this state.
15 (e) Taxable gross receipts from all other items and sources of gross income
16 attributable to this state determined in a manner consistent with the provisions of
17 R.S. 47:287.95 and any related administrative regulations.
18 (18) "Partnership" means a syndicate, group, pool, joint venture, or other
19 unincorporated organization through or by means of which any business, financial
20 operation, or venture is carried on.
21 (19) "Secretary" means the secretary of the Department of Revenue.
22 (20) "Tangible personal property" means and includes personal property,
23 other than immovable property, which may be seen, weighed, measured, felt or
24 touched, or is in any other manner perceptible to the senses.
25 (21) "Taxable gross receipts" means gross receipts less the sum of returns
26 and allowances, cash discounts allowed and taken, and unpaid balances on an
27 account previously included in gross receipts and subsequently found to be bad in
28 accordance with Section 166 of the United States Internal Revenue Code and that are
29 actually charged off for federal income tax purposes.
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1 (22) "Trust" shall have the same meaning as provided by R.S. 9:1731 and
2 includes "electing small business trusts" as defined by Section 1361 of the United
3 States Internal Revenue Code.
4 §288.4. Commercial Activity Tax Calculation
5 A. Except as hereinafter provided, for taxable years beginning on or after
6 January 1, 2018, an annual commercial activity tax shall be paid by every business
7 in accordance with this Part on all Louisiana gross receipts.
8 B. Corporations classified under Subchapter S of the United States Internal
9 Revenue Code as an S corporation shall be subject to the provisions of Subsection
10 C of this Section provided the S corporation excludes all Louisiana taxable income
11 pursuant to R.S. 47:287.732. If the S corporation fails to exclude all Louisiana
12 taxable income pursuant to R.S. 47:287.732, the S corporation shall be subject to the
13 provisions of Subsection D of this Section.
14 C. Except as hereinafter provided, for entities other than corporations, the
15 tax shall be based on gross receipts from all sources, as follows:
16 (1) If gross receipts from all sources is one hundred and fifty thousand
17 dollars or more, but equal to or less than five hundred thousand dollars, the tax shall
18 be two hundred fifty dollars.
19 (2) If gross receipts from all sources is greater than five hundred thousand
20 dollars, but equal to or less than one million dollars, the tax shall be five hundred
21 dollars.
22 (3) If gross receipts from all sources is greater than one million dollars, but
23 equal to or less than one million five hundred thousand dollars, the tax shall be seven
24 hundred fifty dollars.
25 (4) If gross receipts from all sources is greater than one million five hundred
26 thousand dollars, but equal to or less than three million dollars, the tax shall be one
27 thousand five hundred dollars.
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1 (5) If gross receipts from all sources is greater than three million dollars, but
2 equal to or less than six million dollars, the tax shall be three thousand two hundred
3 fifty dollars.
4 (6) If gross receipts from all sources is greater than six million dollars, but
5 equal to or less than twelve million dollars, the tax shall be six thousand five hundred
6 dollars.
7 (7) If gross receipts from all sources are greater than twelve million dollars,
8 the tax shall be twelve thousand five hundred dollars.
9 D. Except as hereinafter provided, for corporations, or those entities electing
10 to be treated and taxed as corporations for federal income tax purposes, the tax shall
11 be the greater of the following:
12 (1) Louisiana corporation income tax as provided by Part II-A of Chapter 1
13 of this Subtitle, after the application of all available credit carryforwards,
14 nonrefundable credits, and refundable credits.
15 (2) An amount, based on gross receipts from all sources, as follows:
16 (a) If gross receipts from all sources are one hundred fifty thousand dollars
17 or more, but equal to or less than five hundred thousand dollars, the tax shall be two
18 hundred fifty dollars.
19 (b) If gross receipts from all sources is greater than five hundred thousand
20 dollars, but equal to or less than one million dollars, the tax shall be five hundred
21 dollars.
22 (c) If gross receipts from all sources is greater than one million dollars, but
23 equal to or less than one million five hundred thousand dollars, the tax shall be seven
24 hundred fifty dollars.
25 (3) If gross receipts from all sources is greater than one million five hundred
26 thousand dollars, an amount equal to thirty-five cents per one hundred dollars of the
27 entity's Louisiana gross receipts.
28 E. For corporations, or those entities electing to be treated and taxed as
29 corporations for federal income tax purposes, engaged in the business of
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1 manufacturing or merchandising or the business of gaming, the tax shall be the
2 greater of the following:
3 (1) Louisiana corporation income tax as provided by Part II-A of Chapter 1
4 of this Subtitle, after the application of all available credit carryforwards,
5 nonrefundable credits, and refundable credits.
6 (2) An amount, based on gross receipts from all sources, as follows:
7 (a) If gross receipts from all sources are one hundred fifty thousand dollars
8 or more, but equal to or less than five hundred thousand dollars, the tax shall be two
9 hundred fifty dollars.
10 (b) If gross receipts from all sources is greater than five hundred thousand
11 dollars, but equal to or less than one million dollars, the tax shall be five hundred
12 dollars.
13 (c) If gross receipts from all sources is greater than one million dollars, but
14 equal to or less than one million five hundred thousand dollars, the tax shall be seven
15 hundred fifty dollars.
16 (3) If gross receipts from all sources is greater than one million five hundred
17 thousand dollars, the lesser of the following:
18 (a) Thirty-five cents per one hundred dollars of the entity's Louisiana gross
19 receipts.
20 (b) Two dollars and seventy-six cents per one hundred dollars of the entity's
21 Louisiana gross profits.
22 §288.5. Requirement to File Consolidated Returns
23 A. Entities shall file consolidated returns in any of the following situations:
24 (1) Except in the case of a single member limited liability company electing
25 to be treated and taxed as a corporation for federal income tax purposes, if a
26 corporation is the sole member of one or more single member limited lability
27 companies, then the corporation shall file a consolidated return and treat the single
28 member limited liability company or companies as a division of the corporation. The
29 corporation shall include the gross receipts of the single member limited liability
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1 company or companies in the corporation's calculation as provided by R.S.
2 47:288.4(D) or (E), and each single member limited liability company or companies
3 shall file a return as provided by R.S. 47:288.4(A), but shall pay only the amount
4 required by R.S. 47:288.4(C)(1), provided the single member limited liability
5 company has the requisite nexus to this state.
6 (2) If a corporation is the sole shareholder of one or more qualified
7 Subchapter S subsidiaries and elects to treat the qualified Subchapter S subsidiary
8 or subsidiaries as disregarded entities for state income tax purposes, then the
9 corporation shall file a consolidated return and treat the qualified Subchapter S
10 subsidiary or subsidiaries as disregarded entities. The corporation shall include the
11 gross receipts of the qualified Subchapter S subsidiary or subsidiaries in the
12 corporation's tax calculation as provided by R.S. 47:288.4(D) or (E), and each
13 qualified Subchapter S subsidiary or subsidiaries shall file a return as provided by
14 R.S. 47:288.4(A), but shall pay only the amount as required by R.S. 47:288.4(C)(1),
15 provided the qualified Subchapter S subsidiary has the requisite nexus to this state.
16 (3) Publicly traded partnerships as defined by Section 7704(b) of the United
17 States Internal Revenue Code shall file a consolidated return and include the gross
18 receipts of their publicly traded partnership affiliates in the publicly traded
19 partnership's tax calculation as provided by R.S. 47:288.4(D) or (E), and each
20 publicly traded partnership affiliate shall file a return as provided by R.S.
21 47:288.4(A), but shall pay only the amount as required by R.S. 47:288.4(C)(1),
22 provided the publicly traded partnership affiliate has the requisite nexus to this state.
23 For purposes of this subsection, "publicly traded partnership affiliates" means any
24 limited liability company or limited partnership for which at least eighty percent of
25 the limited liability company member interests or limited partner interests are owned
26 directly or indirectly by the publicly traded partnership.
27 §288.6. Administrative Provisions
28 A. Entities subject to the tax imposed in this Part shall file a return, on forms
29 prepared by the secretary, on or before the fifteenth day of the fifth month following
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1 the close of the entity's taxable year. The secretary may grant a reasonable extension
2 of time for filing returns, not to exceed six months, from the date the return is due.
3 Requests for filing extensions and returns shall be filed electronically by all entities.
4 B. Entities subject to the tax shall make payments of estimated tax in the
5 same manner as provided by R.S. 47:287.654. Any tax remaining due after making
6 the payments of estimated tax shall be paid by the original due date of the return,
7 subject to the applicable penalties for underpayment of estimated tax as provided by
8 R.S. 47:287.655.
9 C. The secretary may promulgate rules and regulations pursuant to the
10 Administrative Procedure Act for the purposes of administration and enforcement
11 of this Part. Such regulations shall have the full force and effect of law.
12 §288.7. Entities exempt from the tax
13 A. The tax imposed by this Part shall not apply to any of the following:
14 (1) Mutual savings banks, national banking corporations, and banking
15 corporations organized under the laws of the state of Louisiana who pay a tax for
16 their shareholders or whose shareholders pay a tax on their shares of stock under
17 other laws of this state and building and loan associations.
18 (2) Insurance corporations paying a premium tax under Title 22 of the
19 Louisiana Revised Statutes of 1950.
20 (3) Corporations or other entities exempt under Sections 401(a) or 501 of the
21 United States Internal Revenue Code.
22 (4) Religious, educational, charitable, or like corporations not organized or
23 conducted for pecuniary profit.
24 (5) Agencies, instrumentalities, or political subdivisions of the state.
25 (6) Farmers cooperatives as defined in R.S. 47:287.521(A), homeowners
26 associations including those described in Section 528 of the United States Internal
27 Revenue Code, political organizations as defined in Section 527 of the United States
28 Internal Revenue Code, and rural electric and rural telephone cooperatives.
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1 (7) Cooperative, nonprofit membership corporations organized for the
2 purpose of supplying electrical energy and promoting and extended the use thereof
3 as defined in Part I of Chapter 4 of Title 12 of the Louisiana Revised Statutes of
4 1950.
5 B. As used in this Section, "qualified exempt organization" means an entity
6 listed in this Section and shall not include any entity whose exempt status has been
7 disallowed by the Internal Revenue Service. The Department of Revenue may
8 promulgate rules and regulations pursuant to the Administrative Procedure Act to
9 further define "qualified exempt organization" to include an entity for which
10 exemption is constitutionally or legally required, or to exclude any entity created
11 primarily for tax avoidance purposes with no legitimate business purpose.
12 C. Notwithstanding any provision to the contrary, any entity that is owned
13 in whole or in part by a qualified exempt organization shall, in calculating its
14 Louisiana gross receipts or Louisiana gross profits, exclude the proportionate share
15 of its Louisiana gross receipts or Louisiana gross profits attributable to the ownership
16 interest of the qualified exempt organization.
17 Section 2. This Act shall become effective January 1, 2018.
DIGEST
The digest printed below was prepared by House Legislative Services. It constitutes no part
of the legislative instrument. The keyword, one-liner, abstract, and digest do not constitute
part of the law or proof or indicia of legislative intent. [R.S. 1:13(B) and 24:177(E)]
HB 628 Original 2017 Regular Session Jones
Abstract: Imposes a Commercial Activity Tax on the taxable gross receipts of certain
entities doing business in La. and provides for exemptions and administration of the
tax.
Proposed law imposes a Commercial Activity Tax (CAT) on the taxable gross receipts of
each entity doing business in La. CAT is required to be paid by the entity subject to the tax
in addition to any other La. tax for which the entity may be liable.
Proposed law requires business entities, including certain S corporations whose income is
deducted in computing La. corporation income tax liability, to pay a CAT as follows:
(1)$250 if the entity's gross receipts are at least $150K, but equal to or less than $500K.
(2)$500 if the entity's gross receipts are more than $500K, but equal to or less than
$1M.
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(3)$750 if the entity's gross receipts are more than $1M, but equal to or less than $1.5M.
(4)$1,500 if the entity's gross receipts are more than $1.5M, but equal to or less than
$3M.
(5)$3,250 if the entity's gross receipts are more than $3M, but equal to or less than $6M.
(6)$6,500 if the entity's gross receipts are more than $6M, but equal to or less than
$12M.
(7)$12,500 if the entity's gross receipts are more than $12M.
Proposed law requires corporations and entities that are taxed as corporations for federal
income tax purposes, except for corporations engaged in the business of manufacturing or
merchandising, to pay the greater of the following:
(1)The net corporation income tax due after the application of all credit carryforwards,
nonrefundable credits, and refundable credits.
(2)One of the following amounts:
(a)$250 if the entity's gross receipts are at least $150K, but equal to or less than
$500K.
(b)$500 if the entity's gross receipts are more than $500K, but equal to or less
than $1M.
(c)$750 if the entity's gross receipts are more than $1M, but equal to or less than
$1.5M.
(d)0.35% of the amount of gross receipts if the entity's gross receipts are greater
than $1.5M.
Proposed law requires corporations and entities that are taxed as corporations for federal
income tax purposes that are engaged in the business of manufacturing or merchandising or
gaming to pay the greater of the following:
(1)The net corporation income tax due after the application of all credit carryforwards,
nonrefundable credits, and refundable credits.
(2)One of the following amounts:
(a)$250 if the entity's gross receipts are at least $150K, but equal to or less than
$500K.
(b)$500 if the entity's gross receipts are more than $500K, but equal to or less
than $1M.
(c)$750 if the entity's gross receipts are more than $1M, but equal to or less than
$1.5M.
(3)The lesser of the following:
(a)0.35% of the amount of gross receipts if the entity's gross receipts are greater
than $1.5M.
(b)2.76% of the amount of the entity's La. gross profits.
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Proposed law requires consolidated returns to be filed by the following:
(1)A corporation that is the sole member of one or more single member LLCs.
(2)A corporation that is the sole shareholder of one or more qualified Subchapter S
subsidiaries.
(3)Certain publicly traded partnerships.
Proposed law exempts from the CAT the following entities:
(1)Entities with less than $150K in gross receipts.
(2)Non-profit organizations and certain organizations not formed for pecuniary profit.
(3)Certain public utilities.
(4)Certain financial institutions.
(5)Certain insurance companies.
(6)Homeowners associations.
(7)Political organizations.
(8)Rural electric and telephone cooperatives.
Effective Jan. 1, 2018.
(Adds R.S. 47:288.1-288.7)
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