News & Information
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 is treated. The purpose of this briefing book is to provide background information on the interplay of the state and...
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...
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...
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...
80/20 Exclusion Is a Bad Idea for States
Pepsi Tax Case Shows Why 80/20 Exclusion Is a Bad Idea for States In this article, Senior Counsel Bruce Fort explains how the use of the “80/20” company exclusion from several states’ water’s edge combined filing group enables taxpayers to shift domestic income to...
Santa Fe Natural Tobacco Co. v. Dept. of Revenue
The Multistate Tax Commission has filed an amicus brief with the Oregon Tax Court in Santa Fe Natural Tobacco Co. v. Dept. of Revenue. This case considers whether in-state activities conducted by an independent contractor pursuant to a contract with an...
Mobile Workforce Proposals – A Comparison – November 2021 Update
In 2011, the MTC developed model legislation addressing the issue of workers temporarily in the state for short time-periods (“mobile workers”). This was a response to federal legislation that would have preempted state law and which contained provisions that would...
The Commission has Approved Two Uniformity Proposals for Recommendation to the States
The first proposal approved by the Commission is an alternative Model Statute for Combined Reporting following the Finnigan method. This is the method that states are moving toward—which treats the unitary group as a single taxpayer. The second proposal includes...
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