Model Receipts Sourcing Regulation Review Work Group
At its August 2, 2022 meeting, the Uniformity Committee agreed to undertake a project and form a work group to review its model receipts (sales) sourcing regulations for income apportionment purposes, including special industry regulations and more recently adopted market-based sourcing regulations. The goal of this project is to identify updates, corrections, or conforming changes, to consider issues that may not be sufficiently addressed by existing model regulations, and to make recommendations to the committee for its action.
This page includes information on upcoming meetings and agendas, meeting archives, and information and analysis. Those interested in the project can follow the process on this web page and can also contact Brian Hamer, MTC counsel.
Meeting Notice and Agenda
Agenda
We have convened an informal study group of state and industry volunteers to assist staff in identifying issues, addressing questions, and gathering information that may be useful to the Model Receipts Sourcing Regulations Review Work Group. Study group calls are not public but any information that may be useful to the Work Group will be reported out. We will post the next Work Group meeting date here when it is set.
The Work Group and MTC staff welcome input from stakeholders; please contact Brian Hamer, if you would like to provide any input with respect to the ongoing receipts sourcing project.
Dial-in/Log-in Information
None at this time.
Latest Project Documents
- Special Airlines rule draft revision – updated 6/27/2023
- Current MTC model Special Airlines Sourcing Rule
- MTC Airlines Rule sales factor fraction
- Alaska Airlines case (Oregon Tax Court) which addresses the sourcing of codeshare revenue
- Sourcing of Airlines revenue – State chart
- Uri Ben Carmel article in Tax Notes State re nexus
- UPS v. New Mexico Dept. of Tax & Revenue (Ct. of Appeals)
- United Sates v. American Airlines Group Inc.
- Airline card card memo
- Special Airlines rule draft revision – updated 6/2023
- Pros & Cons – Trucking Receipts Sourcing Methods (April 20, 2023)
- Sourcing of Receipts – Airline Chart (April 20, 2023)
- Airline model rule – suggested changes – submitted by M. Harbur (April 20, 2023)
- Notes from the Call of March 16, 2023
- Written Comments from the David Uri Ben Carmel, 349 East Multistate Tax Planning
- Notes from the Call of February 16, 2023
- State Tax Treatment – Sourcing of Trucking Company Receipts (Chart)
- Summary of Montana & New Mexico Decisions
- MTC staff memo on Trucking Company/Transportation Services
- MTC Airline Rule sales factor fraction
- Written Comments from Eversheds Sutherland– submitted Jan. 18, 2023
- Current MTC model Section 17 Regulations
- Current MTC model Special Trucking Rule
- Current MTC model Special Airlines Rule
- Massachusetts Sourcing Rules
- Massachusetts Courier and Package Delivery Services Rule
- Massachusetts Motor Carriers Rule
- New Mexico Tax Court Decision re sourcing of delivery services
- Montana UPS Decision re sourcing of delivery services
Background Information
MTC Model Regulations Addressing Receipts (Sales) Sourcing for Apportionment Purposes
- Model General Allocation and Apportionment Regulations and Summary of General Regulations
- Reformatted Model General Allocation and Apportionment Regulations – in Word with navigation
- Archive from 2017 Revisions to Model General Regulations – Implementing Market-Based Sourcing (Coming soon – Section 1 and 17 Rules page)
- Airlines
- Construction Contractors
- Publishing
- Railroads
- Television and Radio Broadcasting
- Trucking Companies
- Telecommunications and Ancillary Service Providers
- Financial Institutions
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Related Information
- Review of MTC Model Sales/Receipts Sourcing & Special Industry Regulations – Draft Report to the Standing Subcommittee – July 21, 2022
- Overview of Models and Related Documents – Staff Presentation to Standing Subcommittee – June 16, 2022
Other Receipts Sourcing Information
General Method of Market-Based Sourcing of Services Adopted by States for Some or All Services (Including Business Activity Taxes)
Delivery
(MTC Method Generally)
- Alabama
- Colorado
- District of Columbia
- Idaho
- Kentucky
- Louisiana
- Massachusetts
- Montana
- New Hampshire
- New Mexico
- North Carolina
- Oregon
- Pennsylvania
- Tennessee
- Vermont
- West Virginia
Benefit Received
- Arizona – Elective
- California
- Georgia
- Indiana
- Iowa
- Michigan
- Nevada – for CAT
- New Jersey
- Ohio – for CAT
- Rhode Island
- Utah – (Predominant)
- Washington – for B&O Tax
- Wisconsin
