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Chris Lutz Provides Insight to State Tax Notes – Wayfair Should Not Have A Major Impact On Apportionment

State Tax Notes 01/23/2019

An article published by State Tax Notes discusses how States' market-based sourcing rules are likely to undergo scrutiny in the wake of the Wayfair decision that could lead to litigation and new income tax liability.

State and Local Tax attorney, Chris Lutz, said, "he doesn't expect Wayfair to have a major impact on apportionment because most states have taken the position that Quill Corp. v. North Dakota did not apply to income taxes. However, he said that he expects post-Wayfair litigation may arise over throwback and throwout rules, which rely on the taxpayer not being taxable to a destination state and the Joyce rule for combined reporting.

The full article, "Market-Based Sourcing Rules Expected to Draw Litigation," was written by Lauren Loricchio and published by State Tax Notes on December 21, 2018 for its subscribers.

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