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MTC multistate tax Commission
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An intergovernmental state tax agency whose mission is to promote uniform and consistent tax policy and administration among the states, assist taxpayers in achieving compliance with existing tax laws, and advocate for state and local sovereignty in the development of tax policy.
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Commission Files Brief in Tennessee Vodafone Case

The MTC has filed an amicus brief in the Vodafone case before the Supreme Court in Tennessee. The brief addresses the use of UDITPA Section 18 – equitable apportionment authority. The taxpayer argues that under the statutory cost-of-performance rule, sales of mobile telecommunications services to customers in Tennessee should not be sourced to the state. The MTC’s brief argues that the Tennessee Commissioner of Revenue properly used the authority granted under Section 18 to include those sales in the Tennessee sales factor.


You can read the Commission’s brief below.

  • Vodafone Americas Holdings, Inc & Subsidiaries, v. Richard Roberts, Commissioner of Revenue 

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55th Annual Meetings

August 1 - 4, 2022
in Anchorage, Alaska
Schedule of Events  
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State Taxation of Partnerships Work Group

June 27, 2022 - Held bi-weekly 
at 3:00 p.m. Eastern
Via GoToMeeting
View Agenda

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