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Breen Schiller Provides Insight On Departments Of Revenue In Cost-Of-Performance States Finding Ways To Effectively Reach Market-Based Sourcing Without Legislation

State Tax Notes October 23, 2018

An article published by State Tax Notes discusses how departments of revenue in cost-of-performance states are using alternative apportionment to essentially change cost-of-performance sourcing to market-based sourcing.

State and Local Tax attorney, Breen Schiller, stated, "It may be unclear what qualifies as distortion and whether the state has clear guidance, adding that whether the state or the taxpayer bears the burden of proof is another issue." Schiller added, "states with cost-of-performance sourcing generally follow an all-or-nothing approach."

The full article, "State DORs Look to Administratively Reach Market Sourcing," was written by Andrea Muse and published by State Tax Notes on October 22, 2018 for its subscribers.

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