Membership subscription fees charged for nontaxable legal support services were subject to Texas sales and use tax since the seller included them in a lump-sum fee which included payment for the license of document drafting software, which is taxable as tangible personal property. The taxpayer offers legal practice support for a monthly subscription fee, which includes education resources, document drafting tools and access to an online interactive community. The document drafting tools include interactive templates that subscribing members can use to create various legal documents. The taxpayer’s end user license agreement characterizes the document drafting tools as software, and grants subscribing members a license to download the software to a server or other device belonging to the member. The taxpayer only offered the legal support services together with the purchase of the document drafting software license. The taxpayer is selling a license to access and download software, which is subject to tax as tangible personal property. The provision of nontaxable legal support services – education resources and access to an online interactive community – is incident to the sale of the software. As a result, the entire subscription amount is subject to Texas sales and use tax. (Private Letter Ruling No. 2017010166, Texas Comptroller of Public Accounts, July 11, 2018)