January 19, 2018

Appellate decision: Services rendered to clients located outside the city by an attorney working in the city are not taxable as in-city services

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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