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...
An Insider’s View of the MTC’s P.L. 86-272 Project
In the fall of 2018, the MTC’s Uniformity Committee tasked a work group consisting of representatives from a dozen states to update the “Statement Concerning Practices of the Multistate Tax Commission and Signatory States Under Public Law 86-272.” The Statement...
Noell Industries, Inc. v. Idaho State Tax Commission
The Multistate Tax Commission has filed an amicus brief urging the U.S. Supreme Court to review the Idaho Supreme Court's decision in Noell Industries, Inc. v. Idaho State Tax Commission, 470 P.3d 1176 (Idaho 2020). In its decision, the Idaho Supreme Court held...
Hearing Officer Report on Proposed Recommended Amendments to Model Multistate Tax Compact Article IV
In December, 2012, the Multistate Tax Commission Executive Committee approved a public hearing for proposed amendments to Article IV [UDITPA] of the model Multistate Tax Compact. Public Hearing was conducted in March, 2013 by Hearing Officer Professor Richard Pomp,...
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