Florida DOR Determines Taxpayer Should Source Its Corporate Income to Location Where It Provided Services

The Florida Department of Revenue (DOR) Sept. 11, 2020 determined in a letter ruling how Taxpayer should source its income from services it provided. Taxpayer was headquartered in another state and provided its services to customers located in different locations, including Florida. The DOR noted: 1) Taxpayer should source its income from services it provided to the location to which the services were provided, on a market basis; and 2) therefore, the income Taxpayer received from services should appear in both the numerator and the denominator of the Florida sales factor computed in Taxpayer’s Florida corporate income tax return when ...