The Washington Court of Appeals held that a company’s title insurance and escrow services provided remotely should be sourced to Washington because the company’s customers made “first use” of the services in Washington. The trial court held that the services were sourced out-of-state to the remote location where the title company performed its services under RCW 82.32.730(1)(a). Under RCW 82.32.730(1)(a), if the purchaser receives services at the seller’s business location, the services are sourced to that business location. The Court overruled the trial court, holding that subdivision (a) did not apply because the company’s customers did not receive its services at the company’s business locations. The Court ruled that the services should be sourced under subsection (b), which requires sales be sourced to the location where the purchasers “receive” or “make first use of” the taxpayer’s services in Washington.
Chicago Title Ins. Co. v. Dep’t of Revenue, 585 P.3d 162 (Wash. Ct. App. 2026).