Income and franchise tax
Computation, apportionment, sourcing, and withholding questions under state income and franchise tax regimes, including the deviation and adjustment mechanisms that sit behind the standard formulas.
127Income and franchise tax articles
Alabama
1 articleArizona
1 articleCalifornia
55 articles- How does California treat a Section 338(h)(10) election, and where does the gain land in the sales factor?California follows a federal section 338(h)(10) election and taxes the deemed asset sale; substantial, occasional sale receipts stay out of the sales factor.Law as of Oct 13, 2026
- How does a taxpayer petition the Franchise Tax Board for alternative apportionment?A taxpayer petitions California's Franchise Tax Board Chief Counsel in writing under Revenue and Taxation Code section 25137, proposing a substitute method.Law as of Sep 28, 2026
- Can a California service subsidiary of a foreign parent amend prior years to market sourcing, and where does the parent receive the benefit?Yes: a California service subsidiary can amend open years to market sourcing, to the extent its foreign parent receives the benefit outside California.Law as of Oct 15, 2026
- How are asset management fees sourced for California apportionment?From 2026, California sources asset management fees not covered by Regulation 25137-14 to investors' domicile under amended Regulation 25136-2.Law as of Oct 12, 2026
- Can a taxpayer use the installment method for California but not for federal tax purposes?Yes: a taxpayer that elects out of the installment method federally can still use it for California under section 17024.5(e) or 23051.5(e), on Form 3805E.Law as of Oct 13, 2026
- Where is cancellation of debt income sourced for California purposes, for a business and for a nonresident?California apportions business debt discharge income outside the sales factor; a nonresident's personal debt with no California tie has no California source.Law as of Oct 17, 2026
- When does a captive finance subsidiary pay California's higher financial corporation rate?A captive finance subsidiary pays California's 10.84 percent rate if over half its gross income is from dealing in money in competition with national banks.Law as of Oct 13, 2026
- How does California source carried interest when a partner changes residency?California generally sources carried interest paid to a nonresident partner as a distributive share under Regulation 17951-4, whatever the holding period.Law as of Oct 13, 2026
- How does California apportion a charter and aircraft management company, and how far does the air transportation regulation reach?California's air transportation formula (Regulation 25137-7) reaches only passenger and freight hauling; charter management fees follow general rules.Law as of Oct 15, 2026
- Can California tax a nonresident spouse's out-of-state wages through community property?Yes: if a nonresident earner is domiciled in California or another community property state, half the wages are taxed to the spouse still in California.Law as of Oct 9, 2026
- Does a corporate limited partner in an investment fund apportion or allocate its California income?In California, a corporate fund partner ordinarily apportions its share as business income; nonbusiness interest and dividends follow its commercial domicile.Law as of Oct 10, 2026
- How does a corporate partner source gain from selling a partnership interest in California?In California, a corporate partner apportions gain on a partnership interest serving its unitary business, or else allocates it by the partnership's factors.Law as of Oct 13, 2026
- Are sales picked up at a California warehouse California sales for apportionment?Not automatically: California uses the ultimate destination, so goods picked up in California solely to transport out of state can be out-of-state sales.Law as of Sep 28, 2026
- Where does a digital subscription business source California receipts from individual subscribers, and what becomes of the rest?California sources subscription fees to where the subscriber benefits; fees sourced to other states stay in the sales factor denominator, with no throwback.Law as of Oct 17, 2026
- Does owning a disregarded LLC that operates in California give the owner nexus?Yes: a corporation that is the sole member of a disregarded LLC doing business in California is itself doing business there and owes California franchise tax.Law as of Oct 12, 2026
- Is California withholding required on dividends paid to out-of-state owners?Usually not: under California Regulation 18662-4(b)(8), dividends to out-of-state owners need no withholding unless the stock has a California business situs.Law as of Oct 22, 2026
- When do California's bright-line nexus thresholds make a passive investor a taxpayer?A passive investor is doing business in California if its sales, property or payroll, counting pass-through shares, exceed the section 23101(b) thresholds.Law as of Oct 9, 2026
- Does a federal accounting method change automatically apply for California?Per Franchise Tax Board Notice 2024-01, a federal accounting method change generally applies for California only if the state conforms to the underlying law.Law as of Oct 8, 2026
- Does California follow a federal check-the-box entity classification election?Yes: California follows an eligible entity's federal classification under Revenue and Taxation Code Section 23038, and allows only a narrow separate election.Law as of Oct 12, 2026
- Is a federally disregarded limited partnership subject to California's $800 annual tax?No: under Franchise Tax Board Legal Ruling 2019-02, a federally disregarded limited partnership is also disregarded in California and owes no $800 annual tax.Law as of Oct 8, 2026
- Are sales of mortgage notes included in California's sales factor at gross proceeds or net gain?In California's sales factor, mortgage note sales count at gross proceeds for a general corporation, at net gain for a financial one (Regulation 25137-4.2).Law as of Sep 28, 2026
- Does a foreign corporation with no California activity owe California's minimum tax?Not automatically: a foreign corporation owes California's $800 minimum tax only if doing business or qualified there, subject to a first-year exemption.Law as of Oct 12, 2026
- Is a foreign student on a company-funded scholarship taxable in California?A foreign student in California is usually a nonresident; only degree candidates exclude tuition, and living allowances are treated as California source.Law as of Oct 12, 2026
- When are dividends from an insurance company subsidiary deductible in California?California allows an 85 percent deduction for qualified dividends from an insurer owned at least 80 percent, under Revenue and Taxation Code Section 24410.Law as of Oct 12, 2026
- Should a new investment manager and its funds be limited partnerships or LLCs for California and Texas tax purposes?In California an LLC prepays the $800 annual tax and pays a gross income fee, while a limited partnership pays only the $800.Law as of Oct 23, 2026
- Does a California investment partnership owe nonresident withholding or the LLC fee?A qualifying California investment partnership owes no withholding on nonresident partners' securities income, though an LLC fund can still owe the LLC fee.Law as of Oct 13, 2026
- How does California treat IRC 367(d) deemed royalties in worldwide and water's edge years?In California, IRC section 367(d) deemed royalties may be deferred in worldwide combined years; electing water's edge brings the deferred balance into income.Law as of Oct 10, 2026
- Does California tax income a foreign corporation excludes under IRC Section 883?Generally no: California excludes IRC Section 883 income in a water's-edge report by following federal law, and for worldwide filers under section 24320.Law as of Oct 12, 2026
- Can California's large corporate understatement penalty be waived?No: California's large corporate understatement penalty under Revenue and Taxation Code section 19138 is strict liability, with no reasonable cause exception.Law as of Oct 10, 2026
- How does California source receipts from services and intangibles?California sources services where the purchaser gets the benefit and intangibles where used (section 25136); amended Regulation 25136-2 applies from 2026.Law as of Oct 9, 2026
- Is a merger termination fee business income in California, and does it belong in the sales factor?In California, a merger termination fee is usually apportionable business income but is usually kept out of the sales factor.Law as of Sep 28, 2026
- How does a combined group with both financial and general corporations apportion its income?From 2025, California combined groups mixing financial and general members use the single sales factor unless predominantly agricultural or extractive.Law as of Oct 12, 2026
- How does California source a nonresident's compensation and fringe benefits?California sources a nonresident's pay and fringe benefits by where services were performed, generally by California working days over total working days.Law as of Oct 12, 2026
- Is a nonresident's gain from selling a partnership interest California-source income?Generally not: a nonresident's gain on a directly held partnership interest is California-source only if the interest acquired a business situs in California.Law as of Oct 13, 2026
- Can California tax a nonresident shareholder's share of an S corporation's gain on selling its business?Yes, a nonresident shareholder's share of a unitary multistate S corporation's sale gain is California-source to the extent it is apportioned business income.Law as of Oct 13, 2026
- Does California require withholding when a partnership distributes refinancing proceeds?Possibly: California pass-through withholding keys on California source income, not on the cash, so a refinancing distribution can still require withholding.Law as of Oct 12, 2026
- How does California pass-through withholding work for domestic nonresident owners?California pass-through entities generally withhold 7 percent of California-source distributions to domestic nonresident owners paid over $1,500 a year.Law as of Oct 9, 2026
- How does California tax PFIC income when it does not conform to the federal PFIC rules?California does not conform to the federal passive foreign investment company rules; shareholders have California income only on distribution or disposition.Law as of Sep 28, 2026
- Does P.L. 86-272 protect a foreign corporation that sells goods into California?No: California reads Public Law 86-272 as limited to interstate commerce, so it does not shield a non-U.S. seller shipping goods into California from abroad.Law as of Oct 13, 2026
- Where does the dividends paid deduction go on a California REIT return?A real estate investment trust claims the dividends paid deduction on California Form 100 as a California deduction, not within the federal starting point.Law as of Sep 28, 2026
- What happens after an S corporation files a California refund claim?A California S corporation refund claim may be examined by the Franchise Tax Board; shareholders must file their own claims, on their own deadlines.Law as of Oct 8, 2026
- How should an S corporation report a shareholder who left California mid-year, and what does a lower apportionment factor save while the shareholders are residents?On Schedule K-1 (100S), a shareholder who left California mid-year is best shown as a nonresident, with the full-year California-source share in column (e).Law as of Oct 17, 2026
- Is the California S corporation tax deductible on the shareholders' California returns?The 1.5 percent California S corporation tax is deductible federally but not on shareholders' California returns (Revenue and Taxation Code Section 17220).Law as of Oct 12, 2026
- When a seller sells businesses every few years, is a large sale "substantial and occasional" in California, and what does the exclusion do?California drops a substantial, occasional sale's receipts from the sales factor only if outside the seller's normal course; the gain stays taxable.Law as of Oct 15, 2026
- When does a disregarded LLC file a short period California Form 568?A disregarded single member LLC files a short period California Form 568 when its owner closes its books mid-year, because it has no taxable year of its own.Law as of Oct 12, 2026
- How are receipts from services performed at sea sourced for state tax purposes?For tax years before 2026, California sources services performed at sea, outside long-term contracts, by a taxpayer-built approximation such as port days.Law as of Oct 12, 2026
- Does California tax stock options exercised after a move out of state?California usually taxes a nonqualified stock option's spread after a move, sourced by California workdays from grant to exercise or end of employment.Law as of Oct 14, 2026
- Which California businesses still apportion with three factors instead of single sales?From 2025, only a California business with over half its gross business receipts from agricultural or extractive activity keeps three-factor apportionment.Law as of Oct 13, 2026
- Can a website defeat California throwback?When other states treat website cookies and chat as beyond Public Law 86-272, a California seller may be taxable there, so its sales escape throwback.Law as of Oct 14, 2026
- When does California throwback apply, and what makes a taxpayer taxable in another state?California throws back goods shipped from the state unless the seller is subject to income or franchise tax in the buyer's state, or could be.Law as of Sep 28, 2026
- Are California waiting time penalties deductible?California waiting time penalties paid to employees are generally deductible, as IRC section 162(f) reaches payments to or directed by a government.Law as of Oct 10, 2026
- What happens to a California water's edge election when the group reorganizes?A California water's edge election usually survives a reorganization; if electing and nonelecting taxpayers combine, the larger by business assets decides.Law as of Oct 12, 2026
- What happens when California withholding credits do not match the K-1?California credits a partner with the withholding actually remitted for it, so a K-1 that understates withholding does not forfeit the difference.Law as of Oct 14, 2026
- Who is the payee for California withholding when distributions go to a disregarded entity?For California withholding, the payee behind a distribution to a disregarded entity is generally its owner, though Franchise Tax Board forms are less direct.Law as of Oct 9, 2026
- How does a company with no gross receipts apportion its California income?A California company with no gross receipts may petition under Revenue and Taxation Code Section 25137 to apportion by property and payroll instead.Law as of Sep 28, 2026
Colorado
1 articleConnecticut
2 articles- Does Connecticut source a production company's receipts like any other service business?Connecticut sources production company receipts by customer market unless the company is an eligible production entity affiliated with a broadcaster.Law as of Oct 13, 2026
- Does it matter for Connecticut taxes whether real estate is held in an LP or an LLC?For Connecticut taxes, real estate held in an LP or an LLC is treated the same when the entity is a partnership for federal purposes.Law as of Oct 12, 2026
Illinois
1 articleMultistate
42 articles- How does state and local tax fit into the ASC 740 income tax provision?Accounting Standards Codification Topic 740 covers state income-based taxes; sales, property, payroll and most gross receipts taxes fall under Topic 450.Law as of Oct 14, 2026
- Is the billing address a safe proxy for where a service customer receives the benefit?For a business customer, state market-sourcing cascades reach the billing address, if at all, only as the last step, after every other step fails.Law as of Oct 17, 2026
- Which group member must file a state's combined corporate return?Connecticut and the District of Columbia have a taxable common parent file; if not, Connecticut's group chooses and the District uses its most active member.Law as of Oct 13, 2026
- Can a cost-of-performance state end up sourcing service receipts to the customer's location?Sometimes: Oregon, Utah and Pennsylvania rulings read cost-of-performance rules to source service receipts by customer location; the result is not automatic.Law as of Oct 14, 2026
- How are service revenues sourced for state income tax: cost of performance or market?It depends on the state: most now source service receipts by market, as California does, while a minority, including Virginia, still uses cost of performance.Law as of Oct 14, 2026
- Where is self-mined cryptocurrency sourced for state tax purposes when the machines sit in one state and the owner in another?No state has published a sourcing rule for self-mined cryptocurrency: cost of performance favors the machines' state; market rules give it little or nothing.Law as of Oct 14, 2026
- When does a state tax an intercompany gain that the federal consolidated return defers?Separate-entity states tax a federally deferred intercompany gain at transfer; combined states adopting deferral, such as New York, defer it within the group.Law as of Oct 14, 2026
- Which state gets withholding and unemployment insurance when an employee works in more than one state?Income tax withholding follows where the work is done, with the home state as a second layer; unemployment insurance goes to one state under a four-step test.Law as of Oct 17, 2026
- Does an equipment lessor have income tax nexus wherever its lessees take the equipment?Usually yes: equipment located in a state is the lessor's own property there, and the major taxing states treat owned property alone as nexus.Law as of Oct 13, 2026
- When is a seller exempt from Georgia real property withholding, and can a disregarded LLC seller rely on its owner?A nonresident seller avoids Georgia's 3 percent real property withholding only by a listed exemption or by meeting all four deemed-resident conditions.Law as of Oct 17, 2026
- How does Georgia credit nonresident withholding passed up through tiers of partnerships, and why does real property withholding get stuck?Georgia moves nonresident withholding up tiers on Form G2-A; the buyer remits real property withholding on Form G2-RP, and a misnamed credit can get stuck.Law as of Oct 17, 2026
- Does an intercompany service charge to an affiliate in a separate-entity market state create apportionment for the provider?Usually yes: a separate-entity market state counts an intercompany service fee in the provider's receipts, sourced where the affiliate receives the service.Law as of Oct 15, 2026
- How does Pennsylvania tax an investment partnership and its corporate partner, and when does it impute 100 percent apportionment?Pennsylvania taxes individual partners by income class and corporate partners on apportioned business income, and reads an empty sales factor as 100 percent.Law as of Oct 22, 2026
- What belongs in an investment partnership's receipts factor: gross proceeds or net gains, interest, dividends and losses?Each state builds its own receipts factor: some count gross sale proceeds, some count only net gains, and several leave dividends or securities sales out.Law as of Oct 23, 2026
- Do a lower-tier partnership's apportionment factors flow up to its partners?A lower-tier partnership's factors flow up only in aggregate-method states; separate-entity states pass up a sourced amount and entity-level states nothing.Law as of Oct 15, 2026
- How does a lower-tier withholding credit reach the right partner, and what restores one a state has disallowed?States credit nonresident withholding to the taxpayer named on each tier's statement; a disallowed credit returns when the issuer supplies the right document.Law as of Oct 15, 2026
- How do states decide whether to withhold on a nonresident partner's sale gain?Each state decides whether it withholds on nonresident partners at all, which partners, below what de minimis amount, and with what exemptions.Law as of Sep 28, 2026
- Who taxes an opportunity zone deferred gain when the investor changes states before recognition?Ordinarily the state of residence at recognition taxes an opportunity zone deferred gain, but a source state may claim it; California taxed it at the sale.Law as of Oct 14, 2026
- Does an opportunity zone investment get the same treatment in a state that does not conform?A state not conforming to IRC section 1400Z-2, like California, taxes opportunity fund rollover gain at sale and later taxes fund gain federal law excludes.Law as of Oct 13, 2026
- Which apportionment formula does a partnership use where a state offers a choice, keys the formula to an industry code, or meets a factor with a zero denominator?Each state's partnership rule sets the formula, which may differ from the corporate one; a corporate partner combining factors applies its own.Law as of Oct 23, 2026
- Which states require a payment with a partnership's extension, how should a tiered partnership size it, and when are the penalties abated?California, New York, Georgia and Massachusetts extend a partnership's return but not its payments; Texas and New Jersey extend only with a payment.Law as of Oct 23, 2026
- Whose employees are they when a professional employer organization runs payroll?Whether professional employer organization workers leave the client's payroll factor is contested; the model regulation's control test points to the client.Law as of Oct 12, 2026
- Does Public Law 86-272 protection reach a state's minimum franchise tax?No. Public Law 86-272 limits only net income taxes, so a protected company can still owe a state's flat minimum franchise tax; California takes that position.Law as of Sep 28, 2026
- If a partnership elects a pass-through entity tax, does it still withhold for nonresident owners?Unless state law coordinates the two regimes, yes: a pass-through entity tax election does not by itself end the duty to withhold for nonresident owners.Law as of Oct 13, 2026
- Is gain from selling regulatory credits business income or nonbusiness income?Usually business income: regulatory credits generated by operations and sold meet the functional test (California Revenue and Taxation Code section 25120(a)).Law as of Oct 14, 2026
- Must a partnership withhold state income tax for its REIT partner, and how is each state's exemption claimed?Maryland and Utah exclude real estate investment trust partners, Kentucky and Ohio any corporate partner; New York and Illinois withhold absent a certificate.Law as of Oct 15, 2026
- How do states apportion REMIC excess inclusion income?Few states say how to apportion excess inclusion income of a real estate mortgage investment conduit; California Legal Ruling 2009-01 applies the percentage.Law as of Sep 28, 2026
- Which states penalize an undisclosed reportable transaction on a partnership return, and who files the disclosure?A missing reportable transaction disclosure costs a fixed sum in New York, Illinois and Minnesota and a tax-based penalty with a floor in California.Law as of Oct 23, 2026
- What does a revenue recognition change do to state apportionment and sales tax?A revenue recognition change affects state income tax only via federal taxable income, moves the sales factor directly, and sales tax only if invoices change.Law as of Sep 28, 2026
- How do states treat an S corporation's 338(h)(10) election?Conforming states tax a section 338(h)(10) deemed asset sale; New York City and Pennsylvania's personal income tax do not; Tennessee taxes the S corporation.Law as of Oct 12, 2026
- What does a second review of state tax returns look for, and when is it worth doing?A second review of filed state returns, by someone who did not prepare them, looks for refunds and understatements, most usefully before refund periods close.Law as of Oct 12, 2026
- What happens to a state net operating loss when the loss company merges out of existence?States following IRC section 381 pass a merged corporation's net operating loss to the survivor; Tennessee and New Jersey (outside a combined group) do not.Law as of Oct 14, 2026
- When a partnership owns a controlled foreign corporation, which partner's state return carries the Subpart F and GILTI inclusion, and whose factor?Partners, not the partnership, include a controlled foreign corporation's Subpart F and section 951A amounts; none enters the partnership's receipts factor.Law as of Oct 23, 2026
- Can a state apportion the gain when a parent sells a subsidiary it runs separately?Generally not: a gain on stock of a subsidiary that was not unitary with its parent is usually allocated to the parent's commercial domicile, not apportioned.Law as of Oct 14, 2026
- How do apportionment factors roll up through tiers of partnerships, and what happens when a lower tier's data is late, partial or missing?Each tier passes its share of lower-tier apportionment factors up, using the lower tier's year that ends within the owner's year.Law as of Oct 23, 2026
- Who is taxed on a partner's distribution in excess of basis in a tiered structure, and whose apportionment factors apply?The partner whose basis the cash exceeds is taxed as on a sale of its own interest: fully by its home state, elsewhere only under interest-sale rules.Law as of Oct 15, 2026
- What makes two companies one unitary business, and why does it matter?Companies are unitary when functional integration, central management and economies of scale link them; a state may tax an apportioned share of their income.Law as of Oct 14, 2026
- Do receipts no state can source leave the denominator, go to commercial domicile, or dilute every state's factor?Each state answers for itself: some exclude unsourced receipts from the denominator, a few assign them by look-through or domicile, and others leave them in.Law as of Oct 15, 2026
- Who withholds state income tax on a vessel crew's wages?Federal law (46 U.S.C. section 11108) bars state withholding on a qualifying seagoing crew's wages; shipyard or shoreside work can fall outside the rule.Law as of Oct 12, 2026
- How does an upper-tier partnership apportion Virginia income when all it has is K-1 income from lower tiers?Virginia Department of Taxation rulings have an upper-tier partnership apportion with its share of each lower tier's property, payroll and sales.Law as of Oct 17, 2026
- Do nonresident withholding exemption certificates expire, who keeps them, and why will a tax-exempt partner not sign one?State withholding exemption certificates lapse by date, yearly or on changed facts; exempt partners resist certifying no unrelated business taxable income.Law as of Oct 17, 2026
- What happens when every apportionment factor is zero and a state imputes 100 percent?Imputing 100 percent when apportionment factors are zero usually misreads the return; Illinois allocates in full only income derived solely from Illinois.Law as of Oct 14, 2026
New York
9 articles- When can a taxpayer use alternative apportionment in New York?New York allows alternative apportionment if the statutory fraction misreflects New York business income or capital, shown by clear and convincing evidence.Law as of Sep 28, 2026
- How are a broker-dealer's receipts sourced in New York when the business is a partnership?New York sources a broker-dealer partnership's receipts by customer for corporate partners, generally by office for individuals; New York City differs.Law as of Oct 12, 2026
- Does New York tax a nonresident's wages for days worked from home in another state?Usually yes: New York treats a nonresident's day worked at an out-of-state home as a New York day unless the employer's necessity required the work there.Law as of Oct 13, 2026
- Which New York filing fee does a disregarded LLC or limited partnership owe, and when does it owe none?A disregarded LLC with New York source income, gain, loss or deduction owes $25; a disregarded limited partnership owes none under $1 million of gross income.Law as of Oct 23, 2026
- How does New York count workdays when allocating a nonresident's wages?New York allocates a nonresident's wages by New York workdays over total workdays, excluding weekends, holidays, sick days and vacation (20 NYCRR 132.18(a)).Law as of Oct 9, 2026
- Do a UBT-paying partnership's New York City receipts flow to its corporate partner, and how does the UBT paid credit work?New York City has not set how a corporate partner counts receipts of a partnership paying unincorporated business tax; that method sizes the partner's credit.Law as of Oct 17, 2026
- Does a fund or investor owe New York City's Unincorporated Business Tax on trading income?New York City's unincorporated business tax generally exempts trading for one's own account, other than by dealers (Administrative Code section 11-502(c)).Law as of Oct 14, 2026
- Does a single-member LLC owe New York City's Unincorporated Business Tax?A federally disregarded single-member LLC is generally disregarded for New York City's unincorporated business tax, so the tax usually runs through its owner.Law as of Oct 14, 2026
- Do New York's partnership filing fee and the New York City UBT pyramid through tiers of partnerships, and how does California's LLC fee compare?New York's partnership filing fee applies at every tier; New York City credits lower-tier tax; California's LLC fee excludes income already subject to it.Law as of Oct 23, 2026
Ohio
1 articleOregon
2 articles- Does a partnership that owns a single-member LLC doing business in Oregon have filing obligations there?In Oregon, a partnership reports its disregarded LLC's activity, the Corporate Activity Tax ignores disregarded status, and the LLC needs state authority.Law as of Sep 28, 2026
- Does an upper-tier partnership owe Oregon's $150 minimum tax or the corporate activity tax on lower-tier income alone?Oregon's $150 minimum tax applies only if an upper-tier partnership itself does business in Oregon; the Corporate Activity Tax excludes distributive income.Law as of Oct 17, 2026
Tennessee
4 articles- Does building a Tennessee facility through contractors create franchise and excise tax nexus before revenue?Yes: a company building its own Tennessee facility is doing business there, so franchise and excise tax returns are due before the first revenue.Law as of Oct 15, 2026
- Why does Tennessee assess a federally disregarded LLC for franchise and excise tax after it registers for sales tax?Tennessee franchise and excise tax disregards a single-member LLC only if its owner is a corporation; an LLC that files no return can be assessed.Law as of Oct 15, 2026
- How is the Tennessee franchise tax computed for an entity holding real estate in the state?For tax years ending on or after January 1, 2024, Tennessee franchise tax is 0.25 percent of apportioned net worth (minimum $100), with no property measure.Law as of Sep 28, 2026
- How does Tennessee source a fulfillment affiliate's service fees under market-based sourcing?Tennessee sources a fulfillment affiliate's fees to the extent its deliveries for affiliated sellers reach Tennessee recipients (Rule 1320-06-01-.42).Law as of Oct 14, 2026
Texas
6 articles- What happens when a Texas combined group's extension, affiliate list and member reports disagree, and how is it put right?Texas combined group affiliate lists and reports that disagree post as missing or duplicate member filings; new schedules or amended reports cure most.Law as of Oct 17, 2026
- How does an out-of-state entity end its Texas franchise tax account when nexus ends?An entity leaving Texas files a final franchise tax report by the 60th day after nexus ends, pays any tax, and withdraws or notifies the Comptroller.Law as of Oct 17, 2026
- Where does Texas source receipts from digital downloads and licenses for franchise tax?Texas franchise tax sources digital download receipts to the payor's legal domicile and license receipts to the extent the licensed right is used in Texas.Law as of Oct 14, 2026
- When does an out-of-state business owe Texas franchise tax with no Texas footprint?Texas franchise tax nexus starts when an out-of-state entity's Texas gross receipts reach $500,000, with no presence needed; many still owe no tax.Law as of Oct 17, 2026
- Can an LLC be a Texas passive entity, and what does an upper-tier partnership owe when its lower tiers already pay?An LLC cannot be a Texas passive entity, and an upper-tier partnership outside a combined group owes no franchise tax on income from taxable lower tiers.Law as of Oct 17, 2026
- Is the managing member of a Texas LLC doing business in Texas for franchise tax purposes?Being a Texas LLC's managing member does not alone create franchise tax nexus; the member's own Texas activity, services or $500,000 of Texas receipts decide.Law as of Oct 17, 2026
Utah
1 articleWashington
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