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Minnesota Tax Court denies use of Multistate Tax Compact’s equally weighted 3-factor apportionment formula election

The Minnesota Tax Court granted the Minnesota Commissioner of Revenue’s motion for summary judgment on June 19 and denied a taxpayer’s election to use the equally weighted three-factor apportionment formula provided in the Multistate Tax Compact. Minnesota adopted the Compact in 1983, but in 1987, Minnesota specifically repealed Articles III and IV, which provide for the equally weighted three-factor apportionment formula election and the standard apportionment provisions contained in the Compact.

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