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Multistate Tax Alert: Update Regarding the Cook County (Illinois) Non-Titled Tangible Personal Property Use Tax


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On November 26, 2012, a Tax Alert was issued summarizing the provisions of the Cook County Budget for fiscal year 2013 and highlighting an ordinance imposing a new tax on the use of non-titled tangible personal property. The earlier alert addressed the many issues presented by the new tax and the potential that it may be subject to challenge. Although there were concerns raised by various parties regarding the validity of the ordinance, to date we are not aware whether official protests have been filed. Accordingly, it appears that the tax will be in effect April 1, 2013.

The Cook County Department of Revenue (“Department”) has begun sending “Notices” discussing the new tax to businesses located within county boundaries. The Notices include instructions regarding taxpayer registration requirements and provide other information pertaining to compliance. While every “person” who, in the course of business, acquires property subject to the tax is required to register with the Department, the Notice specifies that those businesses that receive the Notice are required to register within 20 days of such receipt. 

In the attached Tax Alert we briefly summarize the new tax and highlight information provided in the Notices and on the Department’s website.

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