The Texas Comptroller of Public Accounts has proposed significant amendments to its service receipts sourcing regulation in the wake of the Texas Supreme Court’s decision in Sirius XM Radio, Inc. v. Hegar, 643 S.W.3d 402 (Tex. 2022). The proposed amendments would dispense with the Comptroller’s long-standing “receipts-producing, end-product act” test…
The Texas Court of Appeals agreed with Sirius XM Radio Inc.’s (Sirius XM) cost-of-performance (COP) method to determine the fair value of Sirius XM’s services performed in Texas. Earlier in this litigation, the Texas Supreme Court found in favor of Sirius XM that origination sourcing, i.e., to where services are…
The Texas Supreme Court issued a decision holding that service receipts are sourced to the physical location of the taxpayer’s personnel or equipment that performed the service for which the customer paid. The decision resolves disagreement regarding the proper interpretation of a Texas franchise tax apportionment statute that addresses the…
Nicole Boutros presents “State Tax Updates and What’s in Store for 2019” during Tax Executives Institute’s Fort Worth Chapter Luncheon on February 27.