Apportionment Double Taxation

News & Analysis as of

Can Taxpayers Find an Advantage in Vodafone Nowhere Income Argument?

It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more

PA Supreme Court Issues Business / Nonbusiness Income Decision

The Pennsylvania Supreme Court has held that a taxpayer’s gain from the sale of timberland was apportionable business income using the “functional test” of Pennsylvania’s amended definition of “business income.” Glatfelter...more

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