A California trial court denied the Franchise Tax Board’s (FTB) motion to vacate and modify the judgment declaring FTB Technical Advice Memorandum (TAM) 2022-01 and FTB Publication 1050 invalid underground regulations adopted...more
The Texas Court of Appeals agreed with Sirius XM Radio Inc.’s (“Sirius SM”) cost-of-performance (“COP”) method to determine the fair value of Sirius XM’s services performed in Texas. Earlier in this litigation, the Texas...more
In the Appeal of Sheward, 2022-OTA-228P (May 25, 2022), the California Office of Tax Appeals (OTA) held the California Franchise Tax Board (FTB) failed to follow its own market-based sourcing apportionment regulation by...more
The American Catalog Mailers Association (ACMA), which describes itself as the nation’s leading industry trade association advocating for catalog, online, direct mail, and other remote-selling merchants and their suppliers,...more
The Texas Supreme Court issued a decision holding that service receipts are sourced to the physical location of the taxpayer’s personnel or equipment that performed the service for which the customer paid. The decision...more