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...

by William Gagnon

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