In a recent decision, the Wisconsin Tax Appeals Commission drew a bright line for sourcing receipts from software for sales factor apportionment purposes: without a contract with the end-user, a company cannot source receipts from software to the end-user’s location. 
Instead, the receipts must be sourced based on the location of the company’s immediate customer, even if most end-users are elsewhere.
Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Nicole Boutros and Evan Hamme will present during Tax Executive Institute’s Wisconsin Chapter Meeting on February 18.
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(This article was originally published by Law360 on March 18, 2019.)
When challenging a state tax assessment outside the tax agency that issued the assessment, taxpayers face a variety of obstacles. One is the presumption of correctness that often attaches to a tax agency’s determination. Judicial deference to a tax agency’s interpretation of a tax statute or regulation makes the taxpayer’s task even more difficult.
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