Tax Appeals Tribunal

'CheckFree' Provides Distinction Between Services and 'Other Receipts'

, New York Law Journal


Tax Appeals Tribunal columnist Joseph Lipari writes that the location to which a "receipt" should properly be attributed for apportioning income of corporations is subject to interpretation, particularly with regard to services. New York moved to establish customer-based sourcing when it enacted in 2014 comprehensive corporate tax reform, but cases under previous law, like the recent determination from the state Division of Tax Appeals in 'CheckFree Services', still offer guidance for issues of classification and location of "receipts" earned by a business.

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