Florida recently issued an unusual ruling that:

  1. Gross receipts from hedging transactions must be excluded from the sales factor, although
  2. Net receipts from output hedges are included, and
  3. Net receipts from input hedges and proprietary trading are excluded

The rule seems to be that all hedging receipts are excluded, unless the hedging activities are connected to making a profit, like the output hedges, in which case the net receipts are included. This is definitely an odd result.Continue Reading Show Me the Money: Florida Issues TAA on Inclusion of Hedging Receipts in Sales Factor