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How Lease Structures & Locations Shape Tax Liability in U.S. Equipment Financing

A Guide to Tax Liability for U.S. Equipment Financing

Tax liability for equipment financing in the U.S. is complex and influenced by several factors. In the first installment of this series, we focused on state-specific regulations and nuances that shape tax outcomes. Here, we delve into the tax methodologies that govern leased equipment, examining how lease structures and equipment locations play critical roles in determining overall tax liability.

 

For a closer look at how these elements impact tax obligations, explore the insights below. 

A Guide to Tax Liability for U.S. Equipment Financing

Tax liability for equipment financing in the U.S. is complex and influenced by several factors. In the first installment of this series, we focused on state-specific regulations and nuances that shape tax outcomes. Here, we delve into the tax methodologies that govern leased equipment, examining how lease structures and equipment locations play critical roles in determining overall tax liability.

For a closer look at how these elements impact tax obligations, explore the insights below. 

Overview of Tax Methodologies

There are three sales tax collection methods for equipment leasing in the U.S.: On Stream (also known as "Rental Stream"), Upfront on Cost, and Upfront on Sum of Receipts. The method applied depends on both the lease structure and state regulations for where the equipment is located. Here's a breakdown of each:

 

Methodology

When is Tax Paid?

Typical Lease Structure(s)1

Can Tax Rate Change?How Tax is Calculated
On StreamWith each rental payment (at the time of invoicing)Fair Market Value (FMV) or Fixed Purchase OptionYesRental payment x tax rate
Upfront on CostAt lease commencement$1 BuyoutNoEquipment cost x tax rate
Upfront on Sum of ReceiptsAt lease commencement$1 BuyoutNoSum of lease payments x tax rate

On Stream

  • When is Tax Paid?: With each rental payment (at the time of invoicing)
  • Typical Lease Structure(s)1: Fair Market Value (FMV) or Fixed Purchase Option
  • Can Tax Rate Change?: Yes
  • How Tax is Calculated: Rental payment x tax rate

Upfront on Cost

  • When is Tax Paid?: At lease commencement
  • Typical Lease Structure(s)1: $1 Buyout
  • Can Tax Rate Change?: No
  • How Tax is Calculated: Equipment cost x tax rate

Upfront on Sum of Receipts

  • When is Tax Paid?: At lease commencement
  • Typical Lease Structure(s)1: $1 Buyout
  • Can Tax Rate Change?: No
  • How Tax is Calculated: Sum of lease payments x tax rate

1These lease structures are commonly associated with each methodology but may not encompass all possible scenarios.

Tax Methodologies by State

Much like other tax codes in the U.S., sales tax methodologies for leased equipment vary by state. No matter which methodology applies, sales tax rates are based on where the equipment is physically located.

 

Full List of States by Lease Structure and Tax Methodology

FMV and Fixed Purchase Option Leases

Alabama, Arkansas, Arizona, California, Colorado, Connecticut, District of Columbia, Delaware, Florida, Georgia, Hawaii, Iowa, Idaho, Illinois, Indiana, Kansas, Kentucky, Louisiana, Massachusetts, Maryland, Maine, Michigan, Minnesota, Missouri, Mississippi, North Carolina, North Dakota, Nebraska, New Mexico, Nevada, New York, Oklahoma, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, Vermont, Washington, Wisconsin, West Virginia, Wyoming

New Jersey, Ohio

$1 Buyout Leases

Colorado, Delaware, Illinois, Missouri, North Dakota, Pennsylvania, South Carolina, South Dakota

Alabama, Arkansas, California, Idaho, New York, Ohio

Arizona, Connecticut, District of Columbia, Florida, Georgia, Hawaii, Iowa, Indiana, Kansas, Kentucky, Louisiana, Massachusetts, Maryland, Maine, Michigan, Minnesota, Mississippi, North Carolina, Nebraska, New Jersey, New Mexico, Nevada, Oklahoma, Rhode Island, Tennessee, Texas, Utah, Virginia, Vermont, Washington, Wisconsin, West Virginia, Wyoming

No Sales Tax on Lease Contracts

Alaska2, Delaware3, Montana, New Hampshire, Oregon

2Some cities/counties in AK assess sales tax, but there is no state-level jurisdiction

3Delaware has a gross receipts tax instead of a sales tax (charged on applicable lease payments)

Reflects tax methodologies as of January 1, 2025, including upcoming changes in Maine and Illinois.

Sample Tax Calculations

The following examples illustrate how various tax methodologies impact overall tax liability. Each scenario represents a 36-month lease for equipment valued at $500,000 in a state with a 10% sales tax rate. Monthly payments are calculated based on standard leasing terms reflecting a rate of 0.0321.

Methodology

Monthly Lease Payment

Monthly Taxes (excluding financing charges)

Total Monthly CostTotal Taxes Over the Lease Term
On Stream$16,050.00$1,605.00$17,655.00$57,780.00
Upfront on Cost$16,050.00$1,388.89$17,655.004$50,000.00
Upfront on Sum of Receipts$16,050.00$1,605.00$17,904.744$57,780.00

On Stream

  • Monthly Lease Payment: $16,050.00
  • Monthly Taxes (excluding financing charges): $1,605.00
  • Total Monthly Cost: $17,655.00
  • Total Taxes Over the Lease Term: $57,780.00

Upfront on Cost

  • Monthly Lease Payment: $16,050.00
  • Monthly Taxes (excluding financing charges): $1,388.89
  • Total Monthly Cost: $17,655.004
  • Total Taxes Over the Lease Term: $50,000.00

Upfront on Sum of Receipts

  • Monthly Lease Payment: $16,050.00
  • Monthly Taxes (excluding financing charges): $1,605.00
  • Total Monthly Cost: $17,904.744
  • Total Taxes Over the Lease Term: $57,780.00

4Assuming tax is financed into the lease. Amounts may vary based on individual lease agreements and local regulations.

Understanding tax liability in U.S. equipment financing is essential for optimizing lease strategies and effectively managing overall tax obligations. By exploring how lease structures and tax methodologies impact tax liability, organizations can make more informed decisions. 
 

First American Equipment Finance, an RBC/City National Bank company, offers tailored guidance for businesses financing equipment and technology—whether operating in the U.S. or abroad. Connect with us today to learn more about our services.

About the Contributor

Alexa Courtney

Alexa Courtney

VP, Sales & Property Tax

Alexa performs tax accounting activities at First American. Her mission is to provide reliable and accurate sales tax and personal property tax information to clients, while administering all tax reporting responsibilities in a timely manner. 

 

This has been prepared for informational purposes only and is subject to change at any time without notice. It is not intended to be used as tax, legal, or accounting advice. Consult with a tax, legal, or accounting professional for guidance.

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