Tennessee DOR Determines Franchise, Excise Tax Sourcing of Receipts Factor for Apportionment

The Tennessee Department of Revenue (DOR) determined in a revenue ruling the sourcing of sales of a company’s product for purposes of the franchise and excise tax apportionment receipts factor. The DOR determined that the taxpayer must source its sales to the location of the wholesale distributors to whom the taxpayer sells the product, and not the location of the subsequent buyers. Sales delivered to wholesale distributors located in Tennessee constitute Tennessee sales and are included in the numerator of the receipts factor. Sales delivered to wholesale distributors located outside Tennessee are not Tennessee sales and are not included in ...