Kendall Houghton, partner in the firm’s State and Local Tax Group, was on the panel of the Paul J. Hartman State and Local Tax Forum, discussing a myriad of current issues in state apportionment formulas—such as the opportunities and pitfalls of market-based sourcing rules—and her comments were featured in State Tax Notes.
“Market-based sourcing has become popular among states,” Houghton said.
“Even where market-based sourcing is not codified, states are sometimes getting to the same result by using Uniform Division of Income for Tax Purposes Act section 18 alternative apportionment,” she said.
Houghton also added that market-based sourcing does not equate to economic nexus, even though some states may assert that it does.
“Market-based sourcing has become popular among states,” Houghton said.
“Even where market-based sourcing is not codified, states are sometimes getting to the same result by using Uniform Division of Income for Tax Purposes Act section 18 alternative apportionment,” she said.
Houghton also added that market-based sourcing does not equate to economic nexus, even though some states may assert that it does.