August 12, 2003

Associated Industries of Florida (AIF) is collecting data on how businesses will be affected by the rule being developed by the Department of Revenue (DOR), which defines the term “substitute communications systems” for the purposes applying the communications services tax.

As we have reported earlier, the rule written by DOR would place an enormous administrative and tax burden on any company with a computer network or in-house telephone system.

To document the broad reach of DOR’s interpretation of the 2001 law implementing this tax as it applies to substitute communications systems, we are asking our members to estimate the amount of tax their companies would have to pay if the rule were to go into effect in its current form. We have developed a worksheet for employers to use in determining the costs they must consider in calculating their tax payment, along with a list of the most commonly used systems that DOR would make subject to the tax.

Once you have calculated your estimated tax, please complete the attached “Estimated Tax Liability” form and fax it to AIF’s Administration Department, at fax number (850) 224-6532. This data will be compiled to create a profile of the impact of the tax on Florida businesses. In order to comply with DOR’s deadline for written comments on the rule, we must receive your form by Thursday, August 21, 2003.

We believe the DOR rule, as it stands now, contradicts what the Legislature intended when it passed the communications services tax into law in 2001. With your assistance, we will be better able to keep this costly and burdensome rule from going into effect.  

Substitute Communications Service Tax Worksheet