News & Analysis as of

Apportionment Gross Receipts Tax

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

Texas Comptroller Takes a Serious Look at Sourcing Regulation After SiriusXM Loss

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

McDermott Will & Emery

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

McDermott Will & Emery on

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

Eversheds Sutherland (US) LLP

New York Senate introduces digital advertising tax bill

On March 13, 2020, New York State Senator and Deputy Majority Leader Michael Gianaris (Democrat) introduced New York S.8056, which would establish a tax on a digital advertiser’s annual gross revenues derived from digital...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

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