The unitary combined reporting method for state corporate income taxation has been adopted by an increasing number of states. While combined reporting requirements vary significantly from state to state, nearly all combined reporting regimes require or allow a water’s-edge method
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Texas Talks: Texas Comptroller amended franchise tax sourcing rules is now final
The Texas Comptroller of Public Accounts amended its franchise tax apportionment rule, as published in proposed form in the March 10 issue of the Texas Register. The rule, which is now final, discards the “receipt-producing, end-product act” test in light…
SALT Pets of the Month: Sunny and Lily
SALT trivia – March 22, 2023
Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!
We will award prizes for the smartest (and fastest) participants.
This week’s question: Which state legislature recently excluded digital advertising taxes from the governor’s…
Wisconsin Tax Appeals Commission finds Skechers’ intercompany transactions lacked a valid business purpose and economic substance
On February 24, 2023, the Wisconsin Tax Appeals Commission upheld the Department’s assessment that Skechers’ licensing transaction with its wholly owned subsidiary, Skechers USA Inc. II (SKII), lacked a valid business purpose and economic substance. On the formation of SKII,…
Illinois DOR issues guidance on taxability of computer software licenses and maintenance agreements
The Illinois Department of Revenue (IDOR) released a general information letter outlining the applicability of Illinois Retailers’ Occupation Tax (ROT) on computer software licenses and maintenance agreements.
The letter states that sales of “canned” computer software are taxable retail sales…
Legal Alert – Tax ins and outs of the New York State budget: Legislative amendments made to Governor Hochul’s Fiscal Year 2024 Executive Budget
TEI’s 73rd Midyear Conference
Next week, Eversheds Sutherland is a proud sponsor of Tax Executives Institute’s (TEI) 73rd Midyear Conference, held this year between March 19-22, 2023 at the Grand Hyatt Hotel in Washington, DC.
Eversheds Sutherland SALT Partners Liz Cha and Charlie…
SALT trivia – March 15, 2023
Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!
We will award prizes for the smartest (and fastest) participants.
This week’s question: The Tax Policy Division of the Texas Comptroller of Public Accounts…
More COP sunshine: Florida gets it, Pennsylvania doesn’t
On March 1, 2023, a Florida Circuit Court rejected the Department of Revenue’s attempt to achieve a market-based sourcing result under Florida’s costs of performance sourcing rule that applies to receipts from services. In Billmatrix Corp. et al. v. Dep’t…