On this episode of Greenberg Traurig’s GeTtin’ SALTy podcast, host Nikki Dobay and guest John Ormonde explore recent developments involving Public Law 86-272 and the limits it may place on state income-taxing authority.
They explain the difference between Joyce and Finnigan apportionment approaches, discuss why the Massachusetts Appellate Tax Board found that the state’s Finnigan rule conflicted with 86-272, and consider potential implications for combined groups and other states.
Their conversation also covers state treatment of internet activities and other services under 86-272, California’s underground-regulation ruling, a Maine liquor case, and whether the statute’s protections could extend beyond sales of tangible personal property.
Nikki and John wrap up with a discussion of their favorite wine regions.
Tune in!
We note the Massachusetts Appeal Board decision has been appealed with a direct review to the Massachusetts Supreme Court pending.