News & Information
Tax Notes – States Article on the Briefing Book
The article from Tax Notes – State, here, speaks to the MTC Briefing Book on new federal rules on NCTI and international business income (see below). Read the article from Tax Notes – State (PDF) Changes in Federal Taxation of Multinational Corporate Groups (PDF)...
Changes in Federal Taxation of Multinational Corporate Groups
Staff of the MTC have prepared this briefing book to update our members on changes to the federal tax system affecting how multinational income and so-called “NCTI” is treated. The purpose of this briefing book is to provide background information on the interplay...
H.R. 8021: More Preemption of State Taxing Authority
The recent United States Budget Reconciliation bill included language that modifies the provisions of P.L. 86-272, the 1959 federal statute that prohibits states from imposing income taxes on out-of-state business if their only activity in a state is soliciting the...
Commercial Domicile: The Crumbling Pillar of Corporate Income Taxation
In the case of certain nonbusiness income, courts and legislatures have long assigned taxing rights to a multistate business’s state of commercial domicile. In this recent article published in Tax Notes State, MTC Senior Counsel Brian Hamer explains that in the...
Commission Files Brief in Cruise Lines International Association, Inc. Case
The MTC has filed a brief in the case of Cruise Lines International Association, Inc., v. Suganuma concerning whether federal courts may assert jurisdiction over a state tax matter where the claim by the taxpayer is barred under the federal Tax Injunction Act, but...
TCJA Effects on State Taxes
In this article recently published in Tax Notes State, MTC Senior Counsel Bruce Fort argues that the states need to re-evaluate their policies regarding conformity to the TCJA to ensure that domestic and multinational companies are being taxed on an equal basis....
MTC Letter to California OTA on Microsoft Case
On May 23, 2024, MTC Executive Director Greg Matson submitted a letter asking the OTA not to make their ruling precedential and explaining that the MTC agrees with the FTB that the result does not fairly reflect California’s share of Microsoft’s income. View...
MTC Files Amicus Brief in Health Net v. Oregon Dep’t of Revenue
On June 16, the MTC filed an amicus brief in Health Net, which is currently pending in the Oregon Supreme Court on direct appeal from Oregon's Tax Court. The case arises out of the same issue as Gillette: whether the state must allow the taxpayer to use the income...
DMA v. Brohl—Is It Time to Stop Fighting the Last War?
Helen Hecht and Lila Disque of the MTC propose that rather than continuing the battle to persuade Congress or the Supreme Court to remove restraints on the states’ existing tax collection mechanism, states might consider an alternative mechanism that makes use of...
DMA and the Overture to Overturn Quill
Helen Hecht and Lila Disque of the MTC consider Justice Kennedy’s concurrence in the Direct Marketing Association case inviting states to bring a challenge to Quill, and the general problems in mounting such a test case. The article also discusses what Justice...
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