intangibles

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New Jersey’s related-member addback provision has five statutory exceptions, but only one is really worthy of comment. 

In their article for State Tax Notes, Sutherland attorneys Leah Robinson and Open Weaver Banks examine the exceptions to New Jersey’s related-member addback provision, focusing on the only exception successfully relied on in the state’s tax court—the…

The Georgia Tax Tribunal has held that an electric utility’s transmission and distribution equipment was not “necessary and integral to the manufacture of tangible personal property” and thus did not qualify for an exemption from Georgia sales and use tax. See Georgia Power Company v. MacGinnitie, Dkt. No. Tax-S&UT-1403540 (Ga. Tax Tribunal, Jan. 5…

By Jessie Eisenmenger and Timothy Gustafson

In a Technical Assistance Advisement, the Florida Department of Revenue determined the proper sourcing methodology for income from twelve different types of sales by an online service provider (OSP) for Florida sales factor purposes. The OSP collects data that it distributes to its customers by a variety of methods,…

By Charlie Kearns
The New York State Department of Taxation and Finance has issued guidance on the sales tax, corporation franchise tax, and personal income tax implications of transactions involving convertible virtual currency, such as bitcoins. The Department’s guidance can be found here. The Department explained in its guidance that convertible virtual currency will be

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At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer pricing program. The MTC also formally announced that Iowa, Pennsylvania and Rhode Island will join the MTC audit program. Additionally, the MTC’s…

On July 28, the Multistate Tax Commission (MTC) Uniformity Committee tabled two projects in order to focus on apportionment regulations in anticipation that the Commission will amend several key UDITPA sourcing rules on Wednesday.
View the full Legal Alert.

On July 28, the Multistate Tax Commission (MTC) Uniformity Committee tabled two projects in order to…

By David Pope and Timothy Gustafson 

The Michigan Court of Appeals held that Thomson Reuters’ sale of Checkpoint, an online tax and accounting research program, was the sale of a nontaxable information service and not tangible personal property for purposes of Michigan’s use tax. The Michigan Department of Treasury argued Checkpoint was tangible personal…