Entertainment Law Update Episode 160 – August/September 2023
Franchise Tax - Apportionment - 34 Tex. Admin. Code § 3.591 (Margin: Apportionment)—The Comptroller adopted his amendments outlined in our previous post to implement the Texas Supreme Court’s opinion in Sirius XM...more
The Texas Comptroller of Public Accounts (the Comptroller) published proposed amendments to Texas’ franchise tax apportionment rule in the January 20 issue of the Texas Register, discarding the now-repudiated...more
On March 25, the Texas Supreme Court issued a highly-anticipated decision concerning the proper test to source receipts from services for purposes of Texas franchise tax. By statute, receipts from a “service performed in this...more
Sirius XM Radio, Inv. v. Hegar (Texas Comptroller of Public Accounts), No. 20-0462, __S.W.3D__ (Tex. March 25, 2022) Issue: Under Texas law, are Sirius XM’s monthly subscription fees from Texas users are receipts from a...more
The Texas Supreme Court issued a decision holding that service receipts are sourced to the physical location of the taxpayer’s personnel or equipment that performed the service for which the customer paid. The decision...more
In a much anticipated opinion addressing Texas franchise tax apportionment, the Texas Supreme Court ruled on 25 March 2022 in favor of the taxpayer, overturning a court of appeals decision that had upheld the Texas...more