The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more
2/18/2025
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Tax Reform
Under a new bill signed into law on March 11, 2024, the South Carolina Department of Revenue will have to satisfy additional standards before it may force affiliated corporate taxpayers to file a unitary combined return. ...more
In a split decision, the Michigan Supreme Court rejected a taxpayer’s assertion that applying the standard apportionment formula to gain derived from a deemed asset sale led to a grossly distorted, unconstitutional result. ...more
On March 1, 2023, a Florida trial court confirmed that costs of performance (COP) sourcing, not market-based sourcing, is Florida’s standard methodology for sourcing service receipts for apportionment purposes. In Billmatrix...more
The Texas Comptroller of Public Accounts has proposed significant amendments to its service receipts sourcing regulation in the wake of the Texas Supreme Court’s decision in Sirius XM Radio, Inc. v. Hegar, 643 S.W.3d 402...more
The Massachusetts Supreme Judicial Court recently held that software vendors have a statutory right to apportion tax on the sale of prewritten computer software purchased for use in multiple states and that they may do so...more