; and to enhance cooperation and coordination among Federal and State tax administrators, consistent with the principle of intergovernmental tax immunity. (c) Secondary Aids to Statutory Construction As a secondary aid in statutory construction, any court, the Secretary, and any sales tax administering authority shall consider— (1) the common law canons of statutory construction, (2) the meaning and construction of concepts and terms used in the Internal Revenue Code of 1986 as in effect before the effective date of this subtitle, and (3) construe any ambiguities in this Act in favor of reserving powers to the States respectively, or to the people. 2. Definitions (a) In General For purposes of this subtitle— (1) Affiliated firms A firm is affiliated with another if 1 firm owns 50 percent or more of— (A) the voting shares in a corporation, or (B) the capital interests of a business firm that is not a corporation. (2) Conforming state sales tax The term conforming State sales tax means a sales tax imposed by a State that adopts the same definition of taxable property and services as adopted by this subtitle. (3) Designated commercial private courier service The term designated commercial private courier service means a firm designated as such by the Secretary or any sales tax administering authority, upon application of the firm, if the firm— (A) provides its services to the general public, (B) records electronically to its data base kept in the regular course of its business the date on which an item was given to such firm for delivery, and (C) has been operating for at least 1 year. (4) Education and training The term education and training means tuition for primary, secondary, or postsecondary level education, and job-related training courses. Such term does not include room, board, sports activities, recreational activities, hobbies, games, arts or crafts or cultural activities. (5) Gross payments The term gross payments means payments for taxable property or services, including Federal taxes imposed by this