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Evaluating Colorado Personnel Resources, Inc. Essay

Decent Essays

The purpose of this Memorandum for Record (“Memo”) is to evaluate Colorado Personnel Resources, Inc.’s (“CPR, Inc.” or “Company”) Hawaii General Excise Tax (“GET”) liability. Specifically, this Memo analyzes issues involving nexus, taxability, tax rate, and penalty waiver. I. General Background By way of background, the Company is in the business of placing Certified Registered Nurse Anesthetists (‘CRNA”) with hospitals, clinics, and similar facilities (“Facilities”) on a contractual basis. Simply put, the Company is providing a specialty contracting service to its clients. The Company identifies and locates Facilities, as well as Facilities seek out the Company, in need of CRNA services. Contracts can be temporary or long-term in duration. In 2007, the Company contracted with a Facility in Hawaii to provide CRNA services. In the initial contract with the Facility, there was no mention of the Hawaii GET; however, in the final contract, the Facility chose to include the GET recovery charge in addition to the agreed-upon monthly contractual amount due. The Company then contracted with various CRNAs in Hawaii to fulfill the terms of the contract with the Facility. The Company also sourced CRNAs from the mainland for temporary assignments when local resources were not available. The Company derives its profit from the difference between what it pays the CRNAs and what it charges the Facilities for the services. Unfortunately, it is not certain whether the CRNA

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