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
Matt Hunsaker breaks down the latest state tax news including a discussion of tax arguments in a controversial civil war era statue removal case, the Texas Supreme Court's decision to hear Sirius XM's apportionment case, and...more
Since 2017, the California Franchise Tax Board has been working on revisions to its regulations for market-based sourcing regulation for income from services and intangibles and for petitioning for alternative apportionment....more
In the wake of the coronavirus pandemic, companies in wide-ranging industries across the country have unprecedented numbers of employees working from remote locations. In a prior post, we discussed numerous issues that may...more
In part 3 of our journey through SALT issues in M&A transactions, Matt Hunsaker highlights a few apportionment, unitary combination, and NOL usage implications that should be on your radar whenever you are involved in a...more
On October 31, 2019, the Wisconsin Court of Appeals rejected the Wisconsin Department of Revenue’s (DOR) position in Wisconsin Department of Revenue v. Microsoft Corporation, Case No. 2018AP2024 that Microsoft should “look...more
The Utah Tax Commission recently ruled in favor of a taxpayer in Case No. 16-155 by authorizing the taxpayer to use a single sales factor for Utah corporate franchise tax... Under Utah law, taxpayers in certain NAICS Codes...more
Two previous Tax Alerts, Tax Provisions in the 2017 Budget Bill (June 20, 2017) and Tax Legislation Enacted During the Regular Session of the 2017 North Carolina General Assembly (June 30, 2017), summarized the major tax...more