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10/30/2023|1 minute read

Of Counsel Mike Semes and Associate Matthew Sommer have written a third and final Tax Notes State article about the significance and ramifications of the Arizona Court of Appeals decision in ADP LLC v. Arizona Department of Revenue, “which stretched the definition of tangible personal property (TPP) to include Software as a Service (SaaS) and therefore subject SaaS to the transaction privilege tax (TPT),” the authors write.

Their article, titled “ADP Certiorari Denial Increases SaaS Uncertainty,” recaps ADP, explains why states have adopted different approaches to taxing digital products (and what some of those approaches have been), and more.

Read the Oct. 23 article (subscription required).


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