Tax Law

Recent Posts

New York Continues to Disregard Taxpayer’s Reliance on Disregarded Entity Rules
Posted on 17 Apr 2020 by Eversheds Sutherland LLP

The New York State Tax Appeals Tribunal affirmed a New York State Division of Tax Appeals determination denying a refund claim to a taxpayer that sought to apply the income sourcing rules for registered broker-dealers to receipts from its separate investment... Read More

Look to Florida: Florida Department of Revenue Provides Guidance for Sourcing Income from Software User Fees
Posted on 20 Mar 2020 by Eversheds Sutherland LLP

The Florida Department of Revenue determined that a platform software company should source its income from user fees and from its sale of services on a market basis, based on the location of the customer to which the services are provided. The platform... Read More

Too Bad, So Sad – Virginia Supreme Court Upholds COP Apportionment Despite Subjecting the Taxpayer to Double Taxation
Posted on 22 Mar 2019 by Eversheds Sutherland LLP

The Virginia Supreme Court held that the use of the cost-of-performance method to apportion nearly 100% of the taxpayer’s sales of services to Virginia did not violate the U.S. Constitution, even though over 95% of the taxpayer’s customers were located... Read More