The Department of Taxation & Finance has issued a technical memorandum regarding the Tax Law § 184 tax on telecommunications services. Technical Memorandum, “Application of Taxation Law Section 184 to Mobile Telecommunication Service Providers,” TSB-M-15(6)C (N.Y.S. Dep’t of Taxation & Fin., July 24, 2015). In an Advisory Opinion issued in the year 2000 (TSB-A-00(18)C), the Department had taken the position that wireless communications service providers that furnish intra-LATA and inter-LATA communications were conducting a local telephone business and were therefore subject to the § 184 tax. In the new TSB-M, the Department states that in light of changes to the telephone industry since 2000, the 2000 Advisory Opinion no longer represents the Department’s position, and that mobile telecommunications service providers are not engaged in a local telephone business and are therefore not subject to the § 184 tax. Such providers may be entitled to refunds of tax to the extent that the statute of limitations for refund is still open.