Successfully defending sales factor sourcing adjustments

In this episode of the SALT Shaker Podcast, host and Associate Chris Lee is joined by Associate Jeremy Gove to discuss a decision by the Indiana Tax Court involving Express Scripts.

Transactions are becoming increasingly more complex. They can involve multiple parties, and multiple types of property and services. There’s also increasing complexity around determining what a party is selling and the type and amount of receipts attributable to that taxpayer. The case Chris and Jeremy discuss addresses income tax apportionment, and whether an activity should be treated as a service, or as a sale of tangible personal property for purposes of a sales factor calculation.

Chris and Jeremy also discuss the evidence used to reach the Indiana Tax Court’s decision.   

Questions or comments? Email SALTonline@eversheds-sutherland.com.