The SALT team represents some of the largest multistate/multinational telecommunication companies on state and local tax matters. Issues we address for our telecommunication clients include:

  • The challenges faced by multistate telecommunication companies regarding the apportionment of telecommunication and data service income
  • The adoption of various market based sourcing methods by a number of states coupled with the application of the cost of performance method
  • Complex apportionment issues giving rise to the development of alternative apportionment methods
  • Challenges resulting from the application of the states' expense add back adjustments to intercompany payments
  • Issues resulting from changing business models with respect to the taxability of bundled telecommunication services provided by companies which may include cloud based products
  • The expanding telecommunication industry into media content in the form of cable or satellite television, resulting in tax issues leveling the tax playing field with traditional media content providers


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