Missouri - Proposed rule would allow taxpayers to elect the new single sales factor method on original returns filed on or after August 28, 2013

myStateTaxOffice
Under a proposed rule filed by the Missouri Department of Revenue on September 18, 2013, corporate taxpayers may generally elect the new single sales factor method on original corporate income tax returns filed on or after August 28, 2013. The proposed rule leaves many open issues, including the level of reliance afforded to taxpayers that file returns before the proposed rule is effective, the method for sourcing sales of services and intangibles, and the statutory support for limiting the new election to originally filed returns.

Since Missouri apportionment elections have historically been irrevocable once made, taxpayers must fully consider the potential impact of any revisions to the proposed rule during the comment period, any new rules that might be proposed addressing open questions, or any unfavorable rulings subsequently issued by the Department or Missouri courts.


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