Foreign Entities Doing Business in the U.S. and Domestic Start-ups: Are you “Wayfair-aware?”

Foreign Entities Doing Business in the U.S. and Domestic Start-ups: Are you “Wayfair-aware?”

Setting the Stage Foreign Direct Investment benefits the United States as foreign companies build new manufacturing and research facilities, creating employment opportunities across the country.  Foreign companies are drawn to the U.S. by its large trading markets, educated workforce and stable political and business environments.  However, a trap for the unwary exists in the form of a disjointed and mostly-unaffiliated U.S. state and local tax regime; over 10,000 distinct tax jurisdictions exist within the U.S., each...

This Little Piggy Goes To Market

This Little Piggy Goes To Market

For three generations (rock and roll, disco and new wave) the sourcing of services for state income tax apportionment didn’t get a whole lot of attention.  Sure, there were rules included in UDITPA (Uniform Division of Income for Tax Purposes Act) that applied to services, but that was just catch-all language for anything “other than tangible personnel property.”  And heck, Congress didn’t even address services when it passed P.L. 86-272, maybe the only law they...