Human Tissue for Research and Training Taxable in Michigan

Friday, March 24th, 2017

Scientist holding a sample near a microscope.

The Michigan Department of Treasury recently ruled that the sale of human tissue for use in research and training is taxable.

The taxpayer was a tissue bank providing human tissue specimens. The tissue could not be transplanted and was therefore only used in medical research and training.

Michigan taxes sales of tangible personal property. Legal transfers of human organs are not taxable because they are considered sales of medical services. Non-transplantable human tissue for sole use in medical research and training is not considered a "human organ." Instead, it is tangible personal property, and its sale is therefore taxable.

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TTR has a website that companies subscribe to and use daily. This website provides a list of everything that can be bought or sold in the U.S. It provides simple answers to whether buying or selling these items is taxable (subject to a sales tax or other tax), and it provides all the legal authority to support these tax answers.

TTR likes to keep things simple and fun, which is why it has great people who provide help to clients on any support questions they have about transaction tax issues.

Please visit TTR on the web at or call 866.578.8193.

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