Generally, the transfer of tangible personal property is the trigger for a sales tax event. In this case, it may be necessary to review the various aspects of a typical transaction to determine if any portion thereof would be subject to sales tax. However, generally speaking, receipts from the sale “Marketing”, "Media Placement Services" and "Web Site Networks" are not subject to State or local sales and compensating use taxes provided your organization does not sell or otherwise transfer any tangible personal property to its clients in conjunction with these activities or perform any services otherwise taxable under Section 1105(c) of the Tax Law in conjunction with these activities. (See, Advertising Agencies, Technical Services Bureau Memorandum, June 10, 1983, TSB-M-83(16)S. For additional guidance, you may also want to refer to Publication 750, A Guide to Sales Tax in New York State http://www.tax.ny.gov/pdf/publications/sales/pub750.pdf. I hope that you find this information useful. Shawn Powell Joseph Reference TSB-A-97(43)s

Pardon my answering a question with a question, but are you looking for specific public examples or individual organizational experiences? As an accounting and management consultants, a few very specific client projects come to mind when considering the answer to this question. I would like to offer examples from two different clients, in two different industries. Example 1: Oil-field Services Organization Company Store Background: First case was the development of a company store for a multi-division oil-field services organization. Historically, all of the divisions of this organization purchased tools, gloves and other miscellaneous items from external vendors. Concept: The concept of the company store was designed to centralize purchasing activities and achieve economy of scale by creating a large purchasing power. The “Company” store not only supplied the divisions with tools, it was also open to the employees and other organizations within the industrial area where it was located. The “Company” store had to have competitive prices and had to win the business of its fellow divisions. Outcome: In 2003 the store generated an average of $50,000 in sales per month. Example 2: Heavy Equipment Leasing Company Background: The second case was engineering company that developed a leaving company for it operating divisions and the general public. The organization sold all of its heavy equipment to a newly-formed, wholly owned subsidiary. The new leasing company then leased the equipment back to the individual divisions and to the general public. Concept: The objective of this project was to increase the rate of utilization of the company’s assets by converting idle time to billable utilization. Outcome: The organization was able to generate revenue from external customers by leasing/renting heavy equipment that was not being fully utilized internally. I am uncertain if these examples will help you with your current project. Should you have any questions, please don’t hesitate to reach out to me at anytime.