Close
Close

Oregon Tax Court holds cable company’s video services subject to special apportionment for broadcasters

The Oregon Tax Court has held that an out-of-state cable company’s video services constituted broadcasting and were subject to the special apportionment provisions for interstate broadcasters for purposes of Oregon corporate excise (income) tax. However, the cable company’s Internet and telephone services were not considered to be broadcasting subject to the special apportionment rules. Under Oregon law, service revenue generally is apportioned using a cost of performance methodology, but interstate broadcasters were required to apportion income from broadcasting during the tax years at issue by using an audience or subscriber factor. The Tax Court determined that each of the company’s services must be evaluated separately to determine whether the broadcasting classification applied.

Download the PDF.