Texas Supreme Court Rejects the “Receipt-Producing, End-Product Act” Sourcing Test

At a glance Schedule a free consultation today to learn more! The full story: In our June 2020 SALT newsletter, we wrote an article summarizing a Texas Court of Appeals decision that applied a “receipt-producing, end-product act” test to the state’s “services performed” sourcing rule to conclude that Sirius’s receipts from subscriptions to its satellite…

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Massachusetts SaaS Company Eligible for Single-Factor Apportionment as a Manufacturer

By: Betsy Goldstein, SALT Manager At a glance The main takeaway: A ruling in Massachusetts concluded that a company’s classification as a manufacturer should not have been revoked on the basis that they sell standardized computer software to customers that is accessed through a Software-as-a-Service platform. As a result, the company saved Massachusetts income taxes…

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Gain From the Sale of Federal Environmental Credits Treated as Apportionable Income in Wisconsin

By: Jess Johannesen, SALT Senior Manager At a glance The main takeaway: A ruling by the Wisconsin Tax Appeals Commission addresses why the sale of federal environmental credits is classified as apportionable income. Assess the impact: Determining whether income should be treated as apportionable can have a significant impact on a corporation’s state income tax…

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