This week, the Multistate Tax Commission (MTC) held its Fall Executive Committee and Uniformity Committee Meetings (in person) in Alexandria, Virginia. During the Executive Committee Meeting, MTC staff approved California’s...more
On March 26th, Kilpatrick Townsend State and Local Tax Partner Jeff Reed presented during a Strafford webinar entitled State Tax Apportionment. The panel discussed state tax apportionment fundamentals and cutting-edge issues....more
When must state apportionment be fair? Always. If a state’s normal apportionment formula is operating unfairly with respect to your company, you need to consider the alternatives. The United States Supreme Court has...more
In a rare special meeting on February 24, 2017, the Multistate Tax Commission (MTC) adopted amendments to the MTC’s Model General Allocation and Apportionment Regulations (Model Regulations) that it has worked on since 2014....more
The Alabama Department of Revenue (ADOR) recently proposed numerous changes to its apportionment rules for corporate income taxpayers, with the stated intention of adopting “recommended amendments to the [Multistate Tax...more
Concluding that the California Legislature (1) is not bound by the Multistate Tax Compact (the “Compact”), (2) had unilateral authority to eliminate the apportionment formula election provision, and (3) clearly intended to do...more
The long saga of Michigan's Multistate Tax Compact election continued on Wednesday with oral argument before the Michigan Court of Appeals. A packed courtroom witnessed a 1.5 hour proceeding before an active three-judge...more
Yesterday, the Multistate Tax Commission (MTC) held its annual meeting in Spokane, Washington. The meeting is the annual event where full MTC member states approve model laws in their final version. The approved versions are...more
Yesterday, the Multistate Tax Commission (MTC) held meetings of its Litigation, Uniformity, and Strategic Planning Steering Committees. The meetings were generally dominated by discussions of evolving apportionment issues,...more
Allied Domecq Spirits & Wines USA, Inc. v. Comm’r of Revenue, 85 Mass. App. Ct. 1125 (2014) - In a unique case, the Massachusetts Appeals Court affirmed a ruling of the Appellate Tax Board (ATB) that two corporations...more
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
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
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