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Gross Receipts Apportionment

Eversheds Sutherland (US) LLP

Better than a box of chocolates: Foreign dividends included in California sales factor denominator

On February 14, 2024, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request for rehearing in the Appeal of Microsoft Corporation and Subsidiaries (OTA Case No. 21037336)....more

Eversheds Sutherland (US) LLP

Reforming San Francisco’s gross receipts tax

On February 5, 2024, the Offices of the Controller and Treasurer & Tax Collector for the City and County of San Francisco published a report outlining tax reform recommendations in time to inform a potential ballot measure...more

Pillsbury - SeeSalt Blog

Maine Expressly Requires Express Scripts to Apportion Services Receipts Using a Look-Through Approach

Pillsbury - SeeSalt Blog on

On November 7, 2023, the Supreme Judicial Court of Maine held a taxpayer’s receipts from the performance of pharmacy benefit management (PBM) services should be apportioned using a look-through approach.  Specifically, the...more

Eversheds Sutherland (US) LLP

Just when you thought you were out: The Maryland Comptroller drops proposed sourcing reg for the digital ad tax 

On August 31, 2021, the Maryland Comptroller filed proposed regulations on the controversial digital advertising gross revenues tax (the DAT) with the Joint Committee on Administrative, Executive, and Legislative Review. Of...more

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