From Cost-of-Performance to Market-Based Sourcing: State Apportionment Shifts in 2025
NEWS & INSIGHTS From Cost-of-Performance to Market-Based Sourcing: State Apportionment Shifts in 2025 From Cost-of-Performance to Market-Based Sourcing: State Apportionment Shifts in 2025 In its May 6, 2025 Apportionment Report, the ABA State and Local Tax (SALT) Committee outlined a continuing trend in state corporate income tax policy: shifting from cost-of-performance (COP) to market-based sourcing. […]
Business vs. Nonbusiness Income in Florida Corporate Tax: A Line More Rigid Than You Think
NEWS & INSIGHTS Business vs. Nonbusiness Income in Florida Corporate Tax: A Line More Rigid Than You Think Business vs. Nonbusiness Income in Florida Corporate Tax: A Line More Rigid Than You Think For multistate corporations navigating Florida’s corporate income tax rules, the difference between business and nonbusiness income isn’t just theoretical—it can determine whether […]
Florida Corporate Income Tax: Including Intercompany Transfers in the Sales Factor
NEWS & INSIGHTS Florida Corporate Income Tax: Including Intercompany Transfers in the Sales Factor Florida Corporate Income Tax: Including Intercompany Transfers in the Sales Factor Overview: Sales Factor Inclusion for Intercompany Transfers Florida’s corporate income tax apportionment rules are layered and complex. While the default formula under section 220.15, Florida Statutes, uses a three-factor […]
Florida Corporate Income Tax Lawsuits Quiet Through Fall as COP Cases Put on Hold
NEWS & INSIGHTS Florida Corporate Income Tax Lawsuits Quiet Through Fall as COP Cases Put on Hold Florida Corporate Income Tax Lawsuits Quiet Through Fall as COP Cases Put on Hold Florida’s most closely watched corporate income tax apportionment cases are now on pause until fall 2025. Lawsuits by Apple, BillMatrix, and […]
Order issued in JetBlue Challenge to Florida’s Airline Special Apportionment Formula
NEWS & INSIGHTS Order issued in JetBlue Challenge to Florida’s Special Apportionment Formula for Airlines JetBlue Survives Motion to Dismiss in Corporate Income Tax Airline Apportionment Case JetBlue has survived the Department of Revenue’s Motion to Dismiss its Complaint challenging Florida’s special apportionment formula for airlines. Known as the “Florida Box,” the formula identifies revenue […]
