Intangible Property Franchise Taxes

News & Analysis as of

Out-of-State Taxpayers Can Reduce Pennsylvania Franchise Tax Under Wynne; Conduct Manufacturing? Your Franchise Tax Should Be Zero...

The Pennsylvania franchise tax has finally expired: 2015 is the last year that taxpayers are required to report and pay it. Because the tax rate has decreased over time, it can be little more than a nuisance for many...more

Sales Factor Sourcing of Services & Intangibles

We still are waiting for the Pennsylvania Department of Revenue (the “Department”) to publish official guidance on the apportionment changes made by Act 52 of 2013. Effective for tax years beginning after December 31, 2013,...more

California Court Finds in Favor of Microsoft, Upholds Costs of Performance

On December 18, 2012, the California Court of Appeal ruled that receipts from the right to replicate software are sourced as sales “other than tangible personal property.” In reversing the trial court, the Court of Appeal...more

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