Florida recently issued an unusual ruling that:
- Gross receipts from hedging transactions must be excluded from the sales factor, although
- Net receipts from output hedges are included, and
- 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.