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
In a recently issued taxpayer-favorable opinion, the Texas Supreme Court overturned the court of appeals’ decision holding that the state’s performance-based sourcing statute for service receipts essentially looks to customer...more
On April 14, 2021, the Connecticut General Assembly’s Joint Committee on Finance Revenue and Bonding introduced SB1106. The bill would establish the “Connecticut Equitable Investment Fund,” which would be funded by, among...more
In mid-January, the Texas Comptroller issued controversial amendments to its franchise (margin) tax apportionment sourcing rules. Are the rules an administrative drift towards market-based sourcing? Matt Hunsaker breaks down...more
The Maryland Medical Cannabis Commission (“the MMCC”) recently reported to the Maryland legislature on “the deleterious effects of the federal tax code on medical cannabis businesses.” As stated in its report, I.R.C. § 280E...more
The San Francisco Gross Receipts Tax (GRT) incorporates provisions of both the federal income tax and the California income and franchise tax. Taxpayers should review their federal and California tax reporting that may impact...more
On June 29, President Obama signed into law the Trade Preferences Extension Act of 2015. Quietly embedded in Section 806 of this new law is a provision that doubled the cap on penalties, from $1.5 million to $3 million, for...more
Fund Managers May Be Taxable in California, Even if the Manager Has No Property or Payroll in California and All of the Management Services Are Performed Outside of the State. Several recent law changes in California,...more
For several years, cases have been piling up in anticipation that Verizon Pennsylvania, Inc. and other taxpayers would be arguing lead cases challenging the application of Pennsylvania’s Gross Receipts Tax to various types of...more