Sutherland SALT Shaker: August 2013 Digest

In this issue:

- No Expressions of Goodwill from Arizona Department of Revenue

- California Court of Appeal: ITFA Doesn’t Make the CUT

- Round We Go: Indiana Denies Taxpayer’s Intercompany “Residual Profit” Deduction Citing Circular Cashflow

- To Market, To Market: Massachusetts Adopts Market-Based Sourcing of Intangibles, Expands Definition of Taxable Services

- The Show Me (the Allocation) State: Passive, Non-Missouri Source Income Allocable as Nonbusiness Income

- Second Circuit Categorizes Dial-Up Internet Services as Telecommunications for Federal Excise Tax Purposes

- Excerpt from: No Expressions of Goodwill from Arizona Department of Revenue:

An Arizona Department of Revenue hearing officer determined that the gross receipts from a taxpayer’s deemed asset sale pursuant to I.R.C. § 338(h)(10), including gross receipts attributable to goodwill, could not be included in the taxpayer’s sales factor for corporate income tax apportionment purposes. The taxpayer asserted that goodwill is an intangible asset, and gross receipts attributable to goodwill should be sourced based on costs of performance, which were outside Arizona...

Please see full newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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