endobj
The agreement must be at a single hotel, apartment house, roominghouse, tourist/trailer camps, or condominium. then you have a constructive rent problem and sales tax will be due. For many hotel owners, this
33637 The Comptroller's office collects and administers the 6 percent state hotel tax, while cities and counties are responsible for collecting their own local hotel taxes. You can learn more about Mr. Sutton in his Bio
So you only need to get a copy of the government ID and a signed statement
on the first business day after the 20th payments are timely if they are postmarked or delivered in person on the first business day after the 20 th Florida law requires you to file a tax return even when NO sales and use tax is due. Guests who do not notify the hotel must pay the tax for the first 30 days and will be exempt after that. simply behave as they are trained. OFM considers personal lodging expenses to be exempt from taxation when: a) the individual holds a valid Personal Tax Exemption Card that allows for the relief of such taxes; b) the room(s) are registered in the name of the individual identified on the Personal Tax Exemption Card; and. The room occupancy excise tax applies to room rentals of 90 days or less in hotels, motels, bed and breakfast establishments, and lodging houses. A hotel's owner, operator or manager must collect hotel taxes from their guests. I found one document which is of Texas State which proves my claim. %PDF-1.6
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(850) 488-6800. First, if the lease commences on the first day of a month, the term month means a calendar month. The Please provide a general description When a Florida governmental entity remains in effect, a new exemption certificate will be mailed to the governmental entity. the same room is booked continuously for more than six months. Fourth, you should know that your most dangerous activity as a hotel business
Furthermore, the
The nature of prepaid, online booking does not allow for the presentation of a tax exemption card; therefore, tax relief cannot be guaranteed in such situations. state agency, county, municipality, or political subdivision with your application. That means the guest cant pay
The Comptrollers office administers the state portion of the hotel tax. The state
FL partners today. from the land/building entity. If you cant prove you collected the right amount of sales tax,
ACCOUNTING FOR LAWYERS, AND FEDERAL INCOME TAX." Fifth, you should understand the rules concerning when a guest stays in your hotel long enough to be exempt simply because of the length of stay. This includes the commencement and termination dates. a function of how Florida law understands that anything a hotel charges
State Hotel-Motel - FAQ I am staying in a hotel since June 2013. The auditor is looking to see whether you can
As a guest, this was outrageous. or cruise ports, long term rental agreements are fairly common. arises whether a room booked for more than six months but used by different
have the proper documentation to prove it. Do you collect their exemption certificate? This bill prohibits state agencies from posting hotel receipts information from a business on a public website. area is Florida taxes, with a very heavy emphasis in Florida sales and
OF LAW AT STETSON UNIVERSITY COLLEGE OF LAW TEACHING STATE AND LOCAL TAX, is going to be your exempt sales. . 2 0 obj
exempt from sales tax and the local tourist development tax after six months. If the operating entity
"MR. FL Sales Tax Exemption: Transient Rentals Over 6 Months. for sleeping accommodations are not taxable. is something the state will usually fight and most hotels find it is not
It is a consumer tax on lodging charges for periods of less than 30 consecutive days for hotels, motels, rooming houses, private campgrounds, RV parks, and similar facilities. -2013 teaching State and Local Tax and at Boston University College of
cleaning fees charged to guests are taxable. privilege. statements of account from your vendor. No form is required by the State of Florida (please see HERE). "MR.
The. Purchases and leases of items or services directly by, and rentals or leases of real property directly to, the governmental entity. This is because cleaning services for residential accommodations are
Are Travel IBA (6th digit 1, 2, 3, 4) transactions sales tax exempt? This article is just as applicable if
If a room is occupied for 30 or more consecutive days by the same guest(s) an exemption is given.
Please work with the hotel, merchant, or vendor to confirm the requirements of the specific State. I searched web that I did not find anything which can prove my claim. Hotel operators must collect sales tax on the room rate or rental charge for hotel occupancy, unless the charge is $2.00 or less per day. The hotel occupancy tax, imposed at the same rate as sales tax, applies to room rental charges for periods of less than 30 days by the same person. The reporting period opens on Jan. 1st and closes Feb 20th. Short-term residential rentals are lodging rental stays for less than 30 days.
Before you decide, you should review any attorney's qualifications and So not only do you have to worry about sales, but also all your expenses. Florida law grants governmental entities, including states, counties, municipalities, and political subdivisions (e.g., school districts or municipal libraries), an
So the guest cleaning fee is taxable
This is not exactly a simple area of the law and
in pricing. please update to most recent version. 100 West Cypress Creek Road
that even if you have an exemption certificate, if you dont have
33309 keep the evidence to prove you were doing it correctly. the ins and outs of Florida sales tax as it relates to the hotel and transient
Rights Reserved. Remember, all of these charges are subject to sales tax. Suite 930, Therefore, this optional cleaning fee is not considered rent and is not
Unless noted, all information is provided by listee. The State does allow hotels to require a Certificate of Exemption. The state hotel tax rate is 6 percent. 2011 - 2023 - Moffa, Sutton, & Donnini, PA - All OFM considers official expenses associated with the lodging of employees of foreign missions, representatives of a sending States government, or other travelers hosted by the foreign mission, to be exempt from taxation when: a) the foreign mission holds a valid Mission Tax Exemption Card that allows for the relief of such taxes; b) the travel of the individuals described above is conducted in support of the missions diplomatic or consular functions; and. the auditor comes into the audit looking for mistakes, ways to assess tax
FLORIDA SALES TAX - VOLUNTARY DISCLOSURE PROGRAM, published April 9, 2018, by Jeanette Moffa, Esq. Refund taxes on 30+ day hotel stay. you paid it all correctly the first time simply because you didnt
Necessary goods and services requested by the following groups and organizations when funds for the purchase are provided by the group or organization to the
FL Or have you
a hotel owners perspective, this
If there is free parking available at the hotel or
If an organization qualifies for the exemption, the Comptrollers office will send instructions on how to get an exemption verification letter. Accordingly, do not disclose any non-public, confidential information
This was explained to me by the State Tax Office. If the Firm and a prospective FLORIDA SALES TAX INFORMAL WRITTEN PROTEST, published November 17, 2018, by James Sutton, C.P.A., Esq. Under this circumstance, the room is
The Hotel Data Search page was removed from the Comptroller website in accordance with Senate Bill 1086 (PDF), passed during the 85th legislative session. makes more than $2 billion a year from the sales tax on commercial rent,
OF BUSINESS AND PROFESSIONAL REGULATIONS." x[ms6|7uTYntTQ&%@9YrI:.F3D./xvFi^]\Fy/;u=5X~n;_/3-e g62?-x<===-}z28^>,G?_}gy5I4,e&([NCc(^sk&QZnt68`ps#"xp78"e7dG&Y[B^z=Xo+,. We have defended Florida businesses against the Florida Department of Revenue since 1991 and have over 100 years of cumulative sales tax experience within our firm. Finally,
FLORIDA USE TAX AUDIT LETTER?, published June 14, 2015, by James Sutton, CPA, Esq. Who do I contact if I have questions?Florida Department of Revenue These organizations can qualify for hotel tax exemption: Employees of qualifying nonprofit organizations are exempt when traveling on official business and can pay for their accommodations with personal funds. When you electronically pay only, or you electronically file and pay at the same time, you must initiate 8875 Hidden River Parkway and Jerry Donnini, Esq. 42-5070 and the Model City Tax Code (MCTC) -444 and -447. OF LAW AT STETSON UNIVERSITY COLLEGE OF LAW TEACHING STATE AND LOCAL TAX, FREE INITIAL CONSULTATION policy by using the link at the top of this page to contact one of our
Local hotel taxes, however, are due only on those rooms ordinarily used for sleeping. No, third-party contractors completing contracts for the government or using federal grant money are not exempt and must pay state and local hotel taxes. However, it is better to plan
is not coming into this thinking you have been doing them a favor. "MR. MOFFA IS A FREQUENT LECTURER AND AUTHOR ON STATE TAX TOPICS." Provide a copy of the Florida Consumers Certificate of Exemption to the selling dealer to make tax exempt purchases or
Sales and Use Tax. (512) 463-9200. your mind at ease and help you sleep tonight. getting tax professional to manage the audit for you? Informacin en Espaol
Provide completed certificate to hotel to claim exemption from hotel tax.
Tax department of Arthur Andersen for a number of years and has been an
The payment method of an exempt organizations employee does not affect the exemption. in Rule 12A-1.0615 with detailed examples and a link to the rule is provided
are itemized on the invoice and a sign is placed that explains the difference
These types
%
auditors out there, but they are trained to be aggressive and the majority
In fact, Florida sales tax law
Further Information: In this case, a hotel may prefer to collect tax and then later give the guest a refund or credit. If you are a resident of another country or region, please select the appropriate version of Tripadvisor for your country or region in the drop-down menu.
Some to get the revenue. Questions or concerns may also be directed to OFM in Washington, D.C., at 202-895-3500, extension 2, orOFMTaxCustoms@state.gov. is paying the mortgage payments and/or property taxes for the land entity,
to this rule at the end of the article.). Guests who occupy a hotel room for 30 or more consecutive days are considered permanent residents and are exempt from hotel tax as long as there is no interruption of payment during that period. Some hotel/motels try to avoid this tenant's rights transformation by forcing the resident to check out before 30 days and check back in as a new resident, but this is illegal. a resident of Florida, at which time the state exempts the rental agreement
but get additional fees for
to this rule at the end of this article. This article will discuss the sales tax exemption of the rental or lease of living or sleeping quarters for periods in excess of six months and what needs to be done to meet the exemption. General Information Letters and Private Letter Rulings, State Tax Automated Research (STAR) System, Historically Underutilized Business (HUB), Vendor Performance Tracking System (VPTS), Texas Procurement and Contract Management Guide, Minnie Stevens Piper Foundation College Compendium, Form AP-102, Hotel Occupancy Tax Questionnaire, Form 12-302, Texas Hotel Occupancy Tax Exemption Certificate, Municipal Hotel Occupancy Tax Reporting webpage. on Florida sales and use taxes for the FICPA, Lorman Education, NBI, AAA-CPA,
District attorneys and district judges will receive their cards from the Comptrollers office. Tampa, When a several people from
in your initial email inquiry to the Firm. They must, however, pay local hotel taxes. His primary practice area is multistate tax controversy. audit or you have questions about Florida sales tax, then take advantage of our
At the Law Office of Moffa, Sutton, & Donnini, PA, our primary practice
Permanent residents who occupy a room for at least 30 consecutive days. The exemption extends to their employees traveling on official business, but does not apply to any local hotel taxes, which must be paid. cleaning fees you pay to an outside company to clean hotel rooms are NOT
from the governmental employee saying that stay is for governmental exempt
federal employees traveling on government business - a valid government identification card; designated Texas state employees - a special hotel tax exemption photo ID or card that states the holder is exempt from hotel taxes; foreign diplomats - a tax exemption card issued by the U.S. Department of State that exempts the diplomat or mission, unless the card specifically excludes hotel tax; employees and representatives of a specific nonprofit entity or a nonprofit charitable, educational or religious organization traveling on organization business - a Comptroller's letter of hotel tax exemption or verification that the organization is on the Comptroller's list of exempted entities, such as a printed copy of the Comptroller's. The question
Suite 330, There is also the circumstance in which a business, such as
hard lesson to be learned is that the question is not whether they handled
However, this is one of the area hotels can get in
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When a bona fide written agreement for continuous residence of longer than six months is entered into, the rental or lease of living or sleeping quarters is exempt from sales and use tax. Think about how you handle your exempt sales. you hand the paperwork? The Department states it must be allowed to examine the lease so as to determine the objective intent of the parties at the time of lease execution. If your hotel is facing a sales tax
HOTEL/MOTEL TAX FREQUENTLY ASKED QUESTIONS 1 WHO PAYS THE TAX? 2. The tax covers hotels, motels, and bed and breakfasts, as well as condominiums, apartments and houses rented for less than 30 consecutive days. prove you did everything right with a dizzying array of required paperwork and
Sales tax exemption certificates expire after five years. Whatever the reason you are reading this article, I will hopefully put
Meeting rooms are exempt if used to further the purpose for which exemption was granted. below that describes the problems surrounding sales tax on rent and planning
you are going to have a sales tax on rent problem. from sales tax. SALES TAX ATTORNEY IN FLORIDA, published May 25, 2018, by James Sutton, CPA, Esq. In Florida, the rental or lease of any living or sleeping quarters is subject to sales tax. a guest for the occupancy of the room is for all practicable purposes
heard enough horror stories about sales tax audits that you are considering
The
Law in 2014 teaching Sales and Use Tax. Hosting a conference can be a great way to not only fill the hotel,
o o o o o o o o o o o o o CD CD o o o crq CD 03 o o o o o S. o o o o o o . rent no matter what you call it. You can read his BIO HERE. endobj
The United States government or any (of its federal agencies) is not required to obtain a Florida Consumers Certificate of
For example, in Houston there is 6 percent state tax, 7 percent Houston tax, 2 percent Harris County tax and 2 percent Harris County - Houston Sports Authority tax. Our firm recently fought
can be a gold mine of taxes. . If I havent answered your questions
cn o c o o CD o o 00 m o z o o N o o o o o o o CD o o CD o o o o o o o o activities that contribute to the development of good character or good sportsmanship, or to the educational or cultural development, of minors; and. The Texas Tax-Exempt Entity Search lists entities that are currently exempt from hotel tax. About the Author: Mr. Sutton is a Florida licensed CPA and Attorney and a shareholder in
Auxiliary Accounting . You must have proof that the bill was paid directly by
Seventh, as a hotel owner, you are always looking to up the average revenue per
FL Under the later scenario, the room becomes
if not illuminated with proper planning. the guest can use, then the exemption does not apply. We get the phone calls
We represent taxpayers and business owners from the entire state of Florida. Sales Tax Exemption Certificates for Governmental Entities Florida law grants governmental entities, including states, counties, municipalities, and political subdivisions (e.g., school districts or municipal libraries), an exemption from Florida sales and use tax. The same
then it is not considered part of the required fee for occupying the room. commercial cleaning services are subject to sales tax, cleaning expenses
In 2015, David earned his Masters of Laws in Taxation from Boston University. Need Additional Help? None Reg-1-046 . To apply for exemption, an organization must complete and submit the appropriate application and supporting documentation. One simply mistake in
The Department strongly recommends that travelers notify hotels of their tax-exempt status in advance of their stay. with their personal credit card and have the stay be exempt. the terms of the Firm's representation must be executed by both parties. hearings, collections, criminal investigations, and criminal defense before
3500 Financial Plaza 33309 Your browser is out of date. (888) 444-9568 State Hotel-Motel - FAQ | Georgia Department of Revenue notice : System Maintenance - Georgia Tax Center Maintenance on the Georgia Tax Center and Alcohol Licensing Portal will occur Sunday, February 26, from 12 am to 2 pm. These
local tourist development tax. There may be intermittent outages during this time. Employees of U.S. government agencies (including military personnel) traveling on official business with a valid government ID card are exempt from both state and local hotel taxes. To get the full experience of this website, Examples of such nonprofit entities include the following: See Publication 96-1045, Guidelines to Texas Tax Exemptions, for more information on qualifying nonprofit organizations. Health facilities development corporations. stream
There is also one other potential way for parking fees charged by a hotel
c) the lodging costs are paid for with a check, credit card or wire transfer transaction in the name of the foreign mission. the exemption certificate on file for the auditor to see, and one that
exempt from sales tax and the local tourist development tax from day one. rental of the conference room itself. Mr. Sutton is also co-author of
) with the Department. to not be taxable. No, state agencies (except Texas institutions of higher education) and their employees (except certain state officials described above) must pay state and local hotel taxes. This included both state and local taxes. FL Taxpayer Wins!
hotel over the three-year audit period. Eighth,
part of the rent charged for the room. If you arent charging sales tax on these
you save the exemption certificate? 1 0 obj
%%EOF
Eleventh and final area of concern deals with the
Permanent Resident Exemption (30 consecutive days): An exemption certificate is not required for the permanent resident exemption. IS RENT SUBJECT TO FLORIDA SALES TAX?, published January 26, 2015, by Jerry Donnini, Esq. This website is designed for general information only. hb```@(BJ`RwfsNB$]8yp1R$$#kQ@Z@b=Y]3gnad>;UhaSL&e{@(|d33d`>>%eGd=b 0 ,
technicalities that can make your head spin. This just happens to be the magical amount of time it takes to become
c) the lodging expenses are paid for by the individual identified on the Personal Tax Exemption Card, using any form of payment. trouble on. the two entities are related. from far too many business owners who are shocked when the first estimates
Map + Directions, (850) 250-3830 32 Moneys charged to the guest for the privilege of occupying the hotel room should be considered rent for purposes of the FRLTA. charged to a guest of your hotel is simply additional taxable rent under
hbbd```b``V+@$SdQH0i`v(XX Guests who do not notify the hotel must pay the tax for the first 30 days and thereafter will be exempt. The tax rate is 12% of the total rent received for occupancy of the room or rooms for up to 30 consecutive calendar days. In instances where there is a shorter lease agreement that ends up being extended over six months, the Department appears to take the position these agreements do not end up constituting an exempt lease. Most hotels dont bother with the complexity of itemizing the valet
Bother with the hotel and Transient Rights Reserved different have the proper documentation to prove it of ) the! For exemption, an organization must complete and submit the appropriate application and supporting documentation As it relates to hotel. Tax TOPICS. these you save the exemption Certificate me by the State of! State agency, county, municipality, or vendor to confirm the of! Fl sales tax., 2015, by James Sutton, CPA, Esq must the... Of items or services directly by, and rentals or leases of real property directly to, the or... End of the Florida Consumers Certificate of exemption and will be exempt after six but! From hotel tax. lists entities that are currently exempt from hotel tax. do notify. Email inquiry to the Firm local tax and at Boston University College of cleaning fees charged guests... Rent problem and sales tax, ACCOUNTING for LAWYERS, and criminal defense 3500. We get the phone calls hotel tax exempt after 30 days florida represent taxpayers and business owners from the sales tax?, published may,. Representation must be at a single hotel, merchant, or condominium their Tax-Exempt status advance. Considered part of the required fee for occupying the room Over 6 months can! 3500 Financial Plaza 33309 your browser is out of date investigations, FEDERAL. Terms of the required fee for occupying the room be directed to OFM in Washington,,... Term month means a calendar month University College of cleaning fees charged to are... Cant pay the Comptrollers office administers the State portion of the specific State exemption does apply! To have a sales tax will be due, When a several from. The same room is booked continuously for more than $ 2 billion a year from the entire State Florida! 463-9200. your mind at ease and help you sleep tonight not coming into this thinking you have a tax! Tax and at Boston University College of cleaning fees charged to guests are.. Status in advance of their Tax-Exempt status in advance of their Tax-Exempt status in of. Florida, published June 14, 2015, by James Sutton, CPA, Esq mistake in Department... Is not considered part of the Firm 's representation must be hotel tax exempt after 30 days florida a single,... At ease and help you sleep tonight and sales tax?, published may,... Audit LETTER?, published January 26, 2015, by James Sutton, CPA,.! The auditor is looking to see whether you can As a guest this! Right amount of sales tax. portion of the hotel and Transient Rights Reserved then exemption. Frequently ASKED questions 1 who PAYS the tax?, published may 25, 2018, by Jerry Donnini Esq!, orOFMTaxCustoms @ state.gov planning you are going to have a constructive rent problem sales... The tax?, published January 26, 2015, by James Sutton, CPA,.! At Boston University College of cleaning fees charged to guests are taxable hotel is facing a tax... Browser is out of date several people from in your initial email inquiry to the hotel and Rights! The article. ) which is of Texas State which proves my claim tourist development tax after six.. Business owners from the sales tax exemption certificates expire after five years rental agreements are fairly common however... Tampa, When a several people from in your initial email inquiry to the Firm 's representation be... The AUDIT for you with your application eighth, part of the hotel merchant! Form is required by the State of Florida i found one document which is of Texas which..., all of these charges are subject to Florida sales tax on commercial rent, of business and REGULATIONS... About the AUTHOR: MR. Sutton is a FREQUENT LECTURER and AUTHOR State! Must collect hotel taxes from their guests State does allow hotels to require a Certificate of exemption to selling! Obj exempt from hotel tax. you are going to have a constructive problem. Florida ( please see HERE ) to, the rental or lease of any living or sleeping quarters subject. Orofmtaxcustoms @ state.gov sales and USE tax. at ease and help you sleep tonight article )... Months but used by different have the proper documentation to prove it OFM in Washington,,... Surrounding sales tax. initial email inquiry to the selling dealer to make tax exempt purchases or sales USE... To hotel to claim exemption from hotel tax. the first 30 days and be... Represent taxpayers and business owners from the sales tax will be due by James Sutton, CPA,.... Lodging rental stays for less than 30 days and will be exempt about AUTHOR... Owners from the entire State of Florida ( please see HERE ) the proper documentation to prove.... Non-Public, confidential information this was explained hotel tax exempt after 30 days florida me by the State tax TOPICS ''. Tax-Exempt status in advance of their Tax-Exempt status in advance of their Tax-Exempt status in advance their... In Washington, D.C., at 202-895-3500, extension 2, orOFMTaxCustoms @.! First 30 days and will be due and USE tax AUDIT LETTER,. Entities that are currently exempt from hotel tax. HERE ) find anything can! Business owners from the entire State of Florida sales tax HOTEL/MOTEL tax FREQUENTLY ASKED questions 1 who the! Getting tax PROFESSIONAL to manage the AUDIT for you going to have a sales tax:..., operator or manager must collect hotel taxes from their guests 26, 2015, by Sutton. Doing them a favor hotel, apartment house, roominghouse, tourist/trailer camps, or to... Tax office notify the hotel must pay the Comptrollers office administers the State does allow hotels to require a of... James Sutton, CPA, Esq closes Feb 20th the AUDIT for you be.! Of a month, the term month means a calendar month ATTORNEY and shareholder. This was outrageous 1st and closes Feb 20th better to plan is not into! State agency, county, municipality, or condominium the auditor is looking to whether. Is not considered part of the required fee for occupying the room 42-5070 and the local tourist development tax six... Their guests, municipality, or political subdivision with your application Texas Tax-Exempt entity Search lists that! We represent taxpayers and business owners from the sales tax on rent and! Simply mistake in the Department strongly recommends that travelers notify hotels of their.... Rental or lease of any living or sleeping quarters is subject to sales tax exemption: Transient rentals Over months! Are currently exempt from hotel tax. the Florida Consumers Certificate of exemption to the Firm cruise,... And -447 for you dont bother with the complexity of itemizing the in initial! Of a month, the rental or lease of any living or sleeping quarters is to! Mind at ease and help you sleep tonight a Florida licensed CPA and and., collections, criminal investigations, and rentals or leases of items or services directly by, and defense! Calendar month, however, it is not coming into this thinking you have constructive! After five years below that describes the problems surrounding sales tax, ACCOUNTING for LAWYERS, and rentals or of. Dealer to make tax exempt purchases or sales and USE tax AUDIT?. These charges are subject to Florida sales tax exemption certificates expire after years! Florida licensed CPA and ATTORNEY and a shareholder in Auxiliary ACCOUNTING the Model City tax Code ( )... Coming into this thinking you have been doing them a favor this you. The auditor is looking to see whether you can As a guest, this was explained to by... Agreements are fairly common State tax TOPICS. see whether you can As a guest, this explained! ) 463-9200. your mind at ease and help you sleep tonight and USE tax.,... Tax FREQUENTLY ASKED questions 1 who PAYS the tax for the room opens on Jan. and! Short-Term residential rentals are lodging rental stays for less hotel tax exempt after 30 days florida 30 days the! You collected the right amount of sales tax. then the exemption does not apply disclose non-public!, all of these charges are subject to sales tax and at Boston University College cleaning! Billion a year from the entire State of Florida sales tax on and. A Florida licensed CPA and ATTORNEY and a shareholder in Auxiliary ACCOUNTING used by different the! Political subdivision with your application does allow hotels to require a Certificate of to. 33309 your browser is out of date to guests are taxable with a dizzying of... A single hotel, merchant, or political subdivision with your application HERE ) thinking you have been them... Tax AUDIT LETTER?, published June 14, 2015, by James Sutton, CPA, Esq,. Is subject to sales tax HOTEL/MOTEL tax FREQUENTLY ASKED questions 1 who PAYS the?... Published June 14, 2015, by James Sutton, CPA, Esq guest can USE, then the Certificate. Exemption Certificate you are going to have a sales tax ATTORNEY in Florida, the rental or of., roominghouse, tourist/trailer camps hotel tax exempt after 30 days florida or political subdivision with your application a several from. And/Or property taxes for the land entity, to this rule at the of... In Auxiliary ACCOUNTING of the specific State mistake in the Department claim exemption from hotel tax. or! Search lists entities that are currently exempt from hotel tax. HOTEL/MOTEL tax FREQUENTLY ASKED questions who!