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Department of Revenue Apportionment

Akerman LLP - SALT Insights

Illinois DOR Proposes to Change Income Tax Liability for Businesses that Make Sales to Foreign Countries

The Illinois Department of Revenue (“IDOR” or “Department”) recently issued a Notice of Proposed Amendment to amend its Regulation (86 Ill. Admin. Code § 100.3200) governing the “throwback” and “throwout” apportionment...more

McDermott Will & Emery

Massachusetts Supreme Judicial Court Approves Sales Tax Apportionment for Software

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On May 21, 2021, the Massachusetts Supreme Judicial Court issued a decision affirming the Massachusetts Tax Appeal Board’s decision in favor of Microsoft and Oracle, ruling that the companies may apportion sales tax to other...more

McDermott Will & Emery

Washington Department of Revenue Announces LendingTree Decision Does Not Prevent Sourcing of Services to Customer's Customer...

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The Washington State Department of Revenue (the “Department”) recently announced its interpretation of the Washington Court of Appeals’ March 30, 2020, adverse ruling in LendingTree, LLC v. Dep’t of Revenue, no. 80637-8-I...more

McDermott Will & Emery

Washington Appellate Court Rejects Department’s B&O Tax Apportionment Method

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In a recently issued taxpayer-favorable opinion, the Washington Appellate Court rejected the apportionment methodology used by the Department of Revenue, which sourced service receipts to the location of a taxpayer’s...more

Smith Anderson

2019 North Carolina Tax Legislation

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This Alert summarizes the more significant tax provisions enacted by the North Carolina General Assembly in 2019.  The most important tax changes were originally included in House Bill 966, the 2019 Appropriations Act (the...more

McDermott Will & Emery

Oregon Bars Use of Three Factor Apportionment Formula

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In Health Net Inc. v. Dep’t of Revenue, Docket No. S063625 (Apr. 12, 2018), the Oregon Supreme Court rejected a business taxpayer’s constitutional challenges to a 1993 Oregon statute that eliminated the right to utilize a...more

Bradley Arant Boult Cummings LLP

Long-Awaited Alabama Tax Amnesty Program Kicks Off

Beginning June 30 and running through August 30, the Alabama Department of Revenue (ADOR) is offering many taxpayers an opportunity to come forward voluntarily and pay a litany of delinquent state and state-administered local...more

Bradley Arant Boult Cummings LLP

Three Important Alabama Regulatory Developments

Last month, the ADOR proposed a new rule, Rule 810-3-35-.01, in order to simplify the federal income tax deduction available to corporations doing business in Alabama. The ADOR proposed to repeal the current corporate federal...more

Bradley Arant Boult Cummings LLP

Alabama Department of Revenue Proposes Changes to its Corporate Income Tax Apportionment Regulations

The Alabama Department of Revenue (ADOR) recently proposed numerous changes to its apportionment rules for corporate income taxpayers, with the stated intention of adopting “recommended amendments to the [Multistate Tax...more

Eversheds Sutherland (US) LLP

It’s Your Burden: South Carolina Supreme Court Rejects Department of Revenue’s Application of Alternative Apportionment

The South Carolina Supreme Court issued its decision in CarMax Auto Superstores West Coast, Inc. v. S.C. Dep’t of Revenue, Opinion No. 27474 (S.C. Dec. 23, 2014), holding that the South Carolina Department of Revenue (the...more

McDermott Will & Emery

Pennsylvania Unwraps Final Market-Sourcing Guidance

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The Pennsylvania Department of Revenue (the Department) recently finalized its Information Notice on sourcing of services for purposes of determining the appropriate net income and capital franchise tax apportionment factors....more

McNees Wallace & Nurick LLC

Focus on Pennsylvania Corporate Taxes

With the November 4th election of Democrat Tom Wolf as Pennsylvania’s next Governor, Pennsylvania corporate taxpayers face an interesting budget season in 2015. During the campaign, Wolf advocated for a severance or...more

Troutman Pepper

Pennsylvania Department Of Revenue Issues Notice On New Receipts Factor Apportionment Rules For Bank Shares Tax

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Immediate Action Required by May 14, 2014 for Any Bank ‘Doing Business’ in Pennsylvania - On April 14, 2014 the Pennsylvania Department of Revenue issued Notice 2014-1 (the Notice). ...more

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