Multistate Tax Commission

In this article for Bloomberg Tax, Eversheds Sutherland attorneys Jeffrey Friedman, Stephanie Do and Michael Hilkin discuss the topics covered at the April 25 Multistate Tax Commission Uniformity Committee meeting in Denver, including revisions to the model combined reporting statute, potential revisions to the MTC’s Public Law 86-272 guidance applicable to businesses engaging in activities

On November 7, 2018, the Multistate Tax Commission’s Uniformity Committee held its fall meeting in Orlando, Florida, where it considered several important topics. Key developments from the Uniformity Committee meeting, include:

• The Committee’s plan to explore updating P.L. 86-272 guidance;
• The progress of the Finnigan Combined Filing Work Group;
• A white paper

In another of the so-called “Compact” cases, the Oregon Supreme Court affirmed the decision of the Oregon Tax Court and held that: (1) the 1967 Oregon Legislature, in enacting Oregon Statute Section 305.655, did not clearly and unmistakably intend for Oregon to enter into a binding contract that would bind the states under the Oregon

It is more complicated to determine an in-state sale regarding the provision of multistate services or licenses of intangibles. Historically, states looked to a taxpayer’s costs of performing the service or licensing the intangible. Some states have become critical of this cost-of-performance method and replaced it with a market-based method of computing in-state sales.

In

Earlier this week, the Multistate Tax Commission held its 2017 March Committee Meetings. Eversheds Sutherland Attorneys were on the scene for all committee meetings. Several interesting and enlightening items were discussed. This alert highlights key developments from the meeting, including:

  • Considerations of developing a model entity-level tax on pass-through entities;
  • The return of the Use

Traditionally, mandatory worldwide combined reporting was the state corporate tax issue of most concern to companies engaged in international business. States are now moving toward a water’s-edge unitary combination method for both US and foreign-based companies.

In his article for the Spring 2017 edition of Partnering Perspectives, Eversheds Sutherland (US) Senior Counsel Eric Coffill covers

In a rare special meeting on February 24, 2017, the Multistate Tax Commission (MTC) adopted amendments to the MTC’s Model General Allocation and Apportionment Regulations that it has worked on since 2014. Among other things, the 94-page Model Regulations:

  • Provide a new section related to market-based sourcing of receipts from the sale of services and

In their article for State Tax Notes, Sutherland attorneys Jonathan Feldman, Stephen Burroughs and Timothy Gustafson analyze the Multistate Tax Commission’s Arm’s-Length Adjustment Service (ALAS) program. While most taxpayers instinctively cringe at any new MTC initiative, the ALAS program is a potential positive for corporate taxpayers due to some disturbing trends arising in state