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Insight

California: Guidance Issued on Alternative Apportionment Requests

In Legal Ruling 19-01, the Franchise Tax Board provides guidance on what it considers to be appropriate subject matter for a request under R&TC section 25137 to vary from the standard apportionment formula.

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Insight

New York: Royalty Payments from Foreign Affiliates Included in Entire Net Income Base

NY Division of Tax Appeals held that for purposes of computing NY entire net income for the tax years at issue, a taxpayer could not exclude royalty payments received from foreign affiliates.

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Insight

Vermont: Market-Based Sourcing Rules Adopted

House Bill 514, signed into law on June 10, 2019, makes certain changes to VT’s tax laws, including the adoption of market-based sourcing.

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The following information is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.