Tax Type
Retail Sales and Use Tax
Description
Nonprofit hospital cooperative
Topic
Exemptions
Date Issued
12-03-1992
December 3, 1992
Re: Request for Ruling: Retail Sales and Use Tax
Dear***************
This will reply to your letter of April 14, 1992 in which you requested a ruling as to whether the**********. (the"Taxpayer") qualifies for exemption from sales and use tax for providing services to**************(the "Hospital").
FACTS
The Taxpayer, a nonprofit research institute, provides support patient care, medical and pharmacologic research, and educational activities exclusively for a publicly supported nonprofit hospital. The Board of Directors of the Taxpayer is comprised of the hospital staff. In addition, the Taxpayer is physically located inside of the hospital but remains a separate corporation from the hospital. The Taxpayer is seeking exemption from the sales and use tax for its purchases of tangible personal property under Va. Code §58.1608(A)(7)(1).
RULING
Va. Code §58.1-608 (A)(7)(1) provides an exemption from sales and use tax for:
-
- Tangible personal property purchased for use or consumption by any nonprofit hospital cooperative or nonprofit hospital corporation organized and operated for the sole purpose of providing services exclusively to nonprofit hospitals. This exemption shall not apply to any nonprofit hospital, cooperative or nonprofit hospital corporation providing services of any kind or to any extent to other than nonprofit hospitals.
- Tangible personal property purchased for use or consumption by any nonprofit hospital cooperative or nonprofit hospital corporation organized and operated for the sole purpose of providing services exclusively to nonprofit hospitals. This exemption shall not apply to any nonprofit hospital, cooperative or nonprofit hospital corporation providing services of any kind or to any extent to other than nonprofit hospitals.
Sincerely,
W. H. Forst
Tax Commissioner
OTP/6105N
Rulings of the Tax Commissioner