Post 30 June

Tracking Use Tax Across Multi-State Shipments: A Tax Manager’s Headache

For tax managers at steel service centers, use tax isn’t just a checkbox—it’s a daily challenge. Every inbound and outbound shipment across state lines opens the door to complex liability, especially when materials are repurposed internally, drop-shipped, or moved between facilities. As states tighten enforcement and expand audit periods, use tax tracking has become a high-stakes game of visibility and control.

Why use tax is such a problem in steel distribution
Use tax is triggered when a business uses, consumes, or stores tangible property in a state where sales tax wasn’t paid. In steel, that scenario happens constantly—whether you’re bending coil into formwork, transferring plate to a job site, or pulling bar stock for internal use.

Unlike sales tax, which is often automated via ERP or POS systems, use tax compliance is decentralized and prone to human error. That’s particularly true for multi-location service centers juggling mixed-use inventory, cross-dock shipments, and custom fabrication.

Common triggers include:

Intercompany transfers: Moving I-beams or angle stock from a warehouse in Indiana to a fabrication shop in Kentucky may incur use tax if the receiving state considers that consumption.

Drop shipments: If a vendor ships directly to your customer in another state, you may still owe use tax if your vendor didn’t collect sales tax.

Internal consumption: Steel used for shelving, racking, or shop fixtures is taxable—yet rarely tracked accurately in real time.

Asset purchases: Buying equipment or tooling from out-of-state vendors without being charged sales tax? You owe use tax in the destination state.

How it slips through the cracks
Steel operations are complex. A single heat number can move through multiple states before it’s sold, transformed, or consumed. Without a clean paper trail and clearly defined tax logic, these movements often get miscategorized.

Disconnected systems
Inventory management systems often don’t “talk” to accounting or tax engines. This leaves use tax reporting disconnected from actual material flow.

Lack of internal documentation
When materials are consumed internally—say, to reinforce racking in the warehouse—there’s rarely a PO or invoice that triggers tax review.

Vendor non-compliance
Some out-of-state suppliers assume they don’t need to collect tax on your purchases. That shifts the burden to you to self-assess use tax and file it correctly.

Confusing state-by-state thresholds
States like California, Washington, and Pennsylvania have different thresholds for triggering nexus and self-assessment. A service center operating in six states may unknowingly miss exposure in two or three.

What tax managers must prioritize
Implement use tax tracking by location
Steel shipments should carry location tags not just for logistics—but for tax. This includes origin, destination, and final point of use. Use tax should be recorded at the point of consumption, not just receipt.

Audit internal transactions quarterly
Review non-resale movements, especially anything involving MRO supplies, steel used in construction or shelving, and asset purchases.

Establish intercompany transfer protocols
When material moves from one subsidiary to another, it should be documented like an external sale—with internal invoices, transfer pricing, and tax logic clearly defined.

Enforce vendor compliance
Push your suppliers to charge sales tax correctly—or provide documentation proving their exemption. Use blanketing logic to flag untaxed purchases from high-risk vendors.

Leverage tax technology
Invest in a tax engine or bolt-on system that integrates with your ERP. Platforms like Avalara, Vertex, or Sovos offer automation tools that can flag high-risk transactions for manual review.

Real pain: audit case studies from the field
A multi-state steel distributor with operations in Ohio, Georgia, and Tennessee was recently assessed $420,000 in back use taxes. The trigger? A mismatch between recorded shipping addresses and final consumption points. Steel rebar shipped from Georgia to Tennessee was consumed internally—but not reported. Auditors reconstructed movement logs and imposed interest on every undocumented transfer.

In another case, a Mid-Atlantic service center failed to file use tax on imported tooling equipment from a vendor in Canada. The equipment was used for custom shearing services, not resale. The result: a use tax assessment of $73,000, plus a penalty for non-filing.

Creating a culture of tax awareness
Use tax compliance can’t sit solely with the tax team. Procurement, operations, and logistics must be part of the equation. Training frontline staff to recognize when use tax applies—especially for internal consumption and asset purchases—will reduce exposure significantly.

Train warehouse staff to document internal usage.

Equip purchasing teams with tax logic guides for different item types.

Assign tax liaisons at each facility to monitor localized compliance.

Staying ahead of the states
More states are using data analytics to identify anomalies in reported use tax. If your reported use tax is consistently zero or unusually low relative to your purchase volumes, you will stand out. Annual reconciliations that map purchases, exemptions, and internal consumption can both validate compliance and reduce audit risk.

In short: assume the auditors are watching. The steel industry’s historically low use-tax reporting rates are now under the microscope—and steel service centers need to shift from reactive to preventative compliance.

Final thought
Use tax in the steel sector is easy to overlook—but impossible to hide. With multi-state shipments, vendor gaps, and internal use scenarios constantly in play, proactive tracking and education are non-negotiable. Tax managers who lead the charge on better documentation and system integration will not only survive the audit era—they’ll turn tax into a strategic advantage.