Apportionment

News & Analysis as of

Delaware Proposes New Bank Franchise Alternative Tax Apportionment Rule

The Delaware State Bank Commissioner proposes to amend Regulation 1114 (Alternative Franchise Tax), which would change the current bank alternative franchise tax apportionment methodology. Interested parties may offer...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Massachusetts Tax Developments: A Reed Smith Quarterly Update (3rd Quarter 2014)

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look back to the developments from the first half of 2014, and look ahead to market-based sourcing and other issues on the...more

The Federal Circuit’s VirnetX Ruling Continues Its Focus On Requirements For Proving Patent Damages

The U.S. Court of Appeals for the Federal Circuit historically has afforded litigants substantial leeway in applying economic theory to establish damages in patent infringement cases, as long as the theories are based on...more

The Expanding Availability of Apportionment To Limit Liability in Superfund Cases

In Burlington Northern in 2008, the US Supreme Court ruled that Superfund liability could be apportioned whenever there was a reasonable basis for showing that the harm was divisible, such as by considering the length of time...more

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

How Will Michigan Courts Analyze a Legal Challenge to the Michigan Legislature’s Retroactive Repeal of the Multistate Tax Compact?

In recent days, the state tax world has focused on the State of Michigan’s retroactive repeal of the Multistate Tax Compact (Compact). Last week, the Michigan Legislature passed and Governor Snyder signed into law a bill...more

Minnesota Issues Revenue Notice Regarding Apportionment of Compensation Paid to Nonresident Corporate Board Members

On August 25, 2014, the Minnesota Department of Revenue released Revenue Notice 14-02, which provides an alternative method of apportioning compensation earned by certain corporate directors who are not residents of Minnesota...more

PA Tax Law News - September 2014

In This Issue: - Sales Factor Sourcing of Services & Intangibles - Nonresident Limited Partners Liable for Personal Income Tax - PA Appeal Systems Changes Update - Personal Responsibility for...more

What's An Apportionment of Your PPD Award?

Forgive me for not explaining the word apportionment sooner in my past blog posts about permanent partial disability awards on Nevada workers' compensation claims. It's a bad word, and it means subtraction from the...more

California Taxpayers: Gillette Still an Option for the 2013 Return

What’s the Option? - We’re all still waiting for a final decision in Gillette. In the meantime, taxpayers have an option for the returns due this fall. They may compute their apportionment using one of the following...more

Senseless (in) Seattle - Confusing application of city’s B&O tax leaves service businesses in a quandary

More than 40 Washington cities impose local business and occupation (B&O) tax. This is in addition to the state’s B&O tax on gross receipts. When a business engages in activities both inside and outside a B&O tax city,...more

Multistate Tax Commission Enacts Significant Amendments to Its Compact

On July 30, the Multistate Tax Commission (MTC) approved amendments to the Multistate Tax Compact’s (1) definition of nonbusiness income, (2) definition of “sales,” (3) factor-weighting, (4) alternative apportionment, and (5)...more

MTC Uniformity Committee Prepares for UDITPA Regulations

On July 28, the Multistate Tax Commission (MTC) Uniformity Committee tabled two projects to free up resources to work on apportionment regulations in anticipation of the full Commission vote later this week that could amend...more

Cross-Border Interest Expense Apportionment Regulations Finalized

The IRS issued cross-border interest apportionment final regulations. These adopt the approach from the 2012 temporary regulations, requiring a 10% corporate partner to apportion its interest expense by reference to the...more

Fast Track for Tax Changes

HB 1050 - Omnibus Tax Changes, which we've written about already this week, was referred to the Senate Finance Committee...more

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

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

New York Budget Legislation

On March 31, 2014, New York State Governor Andrew Cuomo signed into law the 2014-2015 New York State Budget (Budget), which results in the most significant overhaul of New York’s franchise tax in decades. The Budget brings...more

Mississippi Legislature Overwhelmingly Approves Equifax Fix

Earlier this week the Mississippi Legislature approved the conference committee report on tax reform legislation (House Bill 799) that significantly changes Mississippi’s tax assessment and appeals procedures. Both the House...more

Legal Alert: MTC to Explore Apportionment Regulations for Cloud Services, Software and Electricity

While meeting in Denver this week, the Multistate Tax Commission's Income Tax Uniformity Subcommittee advanced two separate projects to develop industry-specific apportionment regulations. One project will look at the...more

Inside the New York Budget Bill Part Three: Apportionment

This is the third installment of a series that takes an inside look at the corporate tax reform proposals in Governor Andrew Cuomo’s 2014–15 New York Budget Bill. This proposed reform is sweeping and, if enacted, is likely to...more

Landlords Welcome Landmark Decision In Re Game Station

LONDON - The Court of Appeal in the case of Re Game Station has held that rent payable by a tenant that enters administration is a priority expense of the administration while the leasehold premises are being used for the...more

Arizona Local Counsel Information

Lewis Roca Rothgerber LLP has prepared this document to inform counsel we work with who are outside of Arizona about certain recurring issues that they should be aware of when litigating here. The document obviously is not...more

Federal Circuit to Review Virginia Court's Decision Excluding Expert Report and Testimony Due to Failure to Apportion Royalty Base...

At the behest of Facebook, Inc., a defendant in a patent infringement case, a Virginia court excluded the report and testimony of a damages expert because the expert failed to apportion the revenue to the features causing the...more

State + Local Tax Insights -- Fall 2013

In This Issue: “Occasional Sales” and Single Sales Factor Apportionment in California; Upcoming Speaking Engagements; State Taxation of Financial Institutions; Applying the True Object Test to Determine the Taxability...more

45 Results
|
View per page
Page: of 2