The Illinois Tax Tribunal issued an order denying PepsiCo Inc. and Affiliates’ (“PepsiCo”) motion for summary judgment and found that PepsiCo’s subsidiary, Frito-Lay North America, Inc. (“FLNA”), was not an excluded 80/20 company and must be include in the PepsiCo Illinois unitary group corporate income tax return.[1] As originally filed, PepsiCo excluded FNLA from

The Illinois Department of Revenue issued a private letter ruling determining that for purposes of the Retailers’ Occupation Tax (“ROT”) and the Services Occupation Tax (“SOT”), a taxpayer that procured marketing materials on behalf of its clients properly sourced these sales to the location of the product manager, the employee responsible for procuring the materials.

The Illinois Department of Revenue issued responses to Frequently Asked Questions regarding marketplace facilitators, marketplace sellers, and remote retailers. The Department considers food ordering and delivery services to be marketplace facilitators if they: (1) list or advertise food or drink for sale by a marketplace seller in a marketplace; and (2) either directly or indirectly,

In February 2021, the Illinois Department of Revenue issued a Compliance Alert on the tax remittance obligations of remote retailers, marketplace sellers, and marketplace facilitators. It concluded that remote retailers and marketplace facilitators must collect and remit state and local retailers’ occupation taxes (ROT) administered by the Illinois Department of Revenue – including the Chicago

After a successful trial-run, the Illinois Department of Revenue (IDOR) recently announced plans to expand its Audit Fast Track Resolution (FTR) program to general income tax disputes in October.

The FTR program allows for the expedited resolution of audit disputes through a conference with a neutral mediator while a case is still under the jurisdiction