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South Carolina ALC interprets income-producing activity method to source receipts via market

On May 12, 2015, the South Carolina Administrative Law Court (ALC) rejected a taxpayer’s attempt to source subscription receipts from South Carolina customers outside of South Carolina based upon a cost of performance methodology. The ALC concluded that the taxpayer’s income-producing activity was the delivery of a signal to the customer’s home. Therefore, all of the subscription receipts from South Carolina customers were sourced to the numerator of the gross receipts ratio.

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