KPMG reports - Arizona (unitary group); Colorado (digital images); Colorado (single-employee nexus); Oregon (sales factor) 

December 16:  KPMG’s This Week in State Tax—produced weekly by KPMG’s State and Local Tax practice—focuses on recent state and local tax developments and features a series of short podcasts presented by KPMG tax professionals. Text of the podcasts is also available.

This week’s edition includes the following topics (listen to the podcasts; to read text, click on the links below).


  • Arizona - The Arizona Court of Appeals held that a home improvement retailer must include its wholly owned intangible holding company in its Arizona unitary combined return because, although the companies were separate organizations, their operations were substantially interrelated.


  • Colorado - The Colorado Department of Revenue issued a private letter ruling concluding that receipts from sales of digital images must be sourced, for corporate income tax purposes, as income from the sale of tangible personal property. Thus, the sales must be sourced under the destination-based rules.


  • Colorado - The Colorado Department of Revenue issued a general information letter finding that the presence of a single, telecommuting employee may create nexus for an out-of-state S corporation.


  • Oregon - The Oregon Supreme Court affirmed a state tax court decision that receipts from the sale of certain intangible assets and goodwill are excluded from the Oregon sales factor.



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