In a published decision issued Thursday, the Michigan Court of Appeals held that income received for legal services rendered by an attorney working in the City of Detroit to a client located outside the city are “out-of-city” services for purposes of determining income taxable by the city.
Honigman Miller Schwartz and Cohn LLP v City of Detroit. The Court’s first paragraph synopsis states:
“We are asked in this case to determine whether services performed by an attorney in Detroit on behalf of a client located outside the city while that attorney is physically located in his or her office in the city is to be considered in-city or out-of-city income for purpose of § 23 of the City Income Tax Act (CITA).1 Petitioner maintains that the relevant consideration is where the client receives the services, while respondent and the Tax Tribunal maintain that the relevant consideration is where the work is performed. We agree with petitioner and reverse the Tax Tribunal and remand.”
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