For over 65 years, Public Law 86-272 has dictated a state’s ability to assert income tax on an out-of-state business. While the 1959 federal law predated the emergence of e-commerce and digital services and could not have...more
6/4/2025
/ Business Entities ,
E-Commerce ,
Government Agencies ,
Income Taxes ,
Judicial Authority ,
Multistate Tax Commission (MTC) ,
New Legislation ,
Proposed Legislation ,
Regulatory Authority ,
State Taxes ,
Statutory Interpretation
The Illinois Department of Revenue (“IDOR” or “Department”) recently issued a Notice of Proposed Amendment to amend its Regulation (86 Ill. Admin. Code § 100.3200) governing the “throwback” and “throwout” apportionment...more
In a recently issued taxpayer-favorable opinion, the Texas Supreme Court overturned the court of appeals’ decision holding that the state’s performance-based sourcing statute for service receipts essentially looks to customer...more
4/21/2022
/ Economic Realities Test ,
Gross Receipts ,
Income Apportionment ,
Income Taxes ,
Principal Place of Business ,
Radio Broadcasting ,
SALT ,
Satellites ,
SiriusXM ,
Subscription Services ,
Tax Audits ,
Tax Liability ,
Texas ,
TX Supreme Court
The federal government has enacted two tax measures to combat the financial downturn resulting from the coronavirus pandemic. The President signed into law a bill that includes a 100 percent payroll tax credit for certain...more