Franchisor and State Income Tax Nexus

Technical topics regarding tax preparation.
#1
JCCPA  
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175
Joined:
23-May-2014 2:00pm
Location:
New Hampshire
Hi All:

I have been working with a client who is opening Franchises all over the country. I would estimate that they now have Franchises in approximately 10 states, or will, by the end of 2018.

We have been researching states' filing obligations for Franchisors. All the Franchisees are paying royalties and using the Franchisor's Trade Name and Trade Marks.

I am familiar with the Geoffrey case as well as certain state income tax nexus concepts. I also understand that this does not fall under Public Law 86-272, as it is strictly intangible related.

My client and I have been trying to find a single source that might summarize Franchisor/Nexus with respect to every State. I am starting to think that there isn't a single source that summarizes State nexus in this situation.

Obviously, we can start looking at every state's laws and rules, but this is super time consuming.

Additionally, client is a pass-through entity (multi-person LLC), thus creating potential individual filing obligations in each State.

Regardless, I figured I'd post here in the Forum to see if anyone has any pointers and ideas.

Thank you to anyone and everyone, in advance, for any assistance.

~J
 

#2
sjrcpa  
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6471
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23-Apr-2014 5:27pm
Location:
Maryland
Checkpoint state and local service. Has all states laws. Can produce Nexus charts. I think you'll have to drill down deeply for franchise nexus, but general nexus rules woukd apply.
Last edited by sjrcpa on 25-May-2018 9:35am, edited 1 time in total.
 

#3
JCCPA  
Posts:
175
Joined:
23-May-2014 2:00pm
Location:
New Hampshire
Thanks, SJR.

I think this is it....that's the book version, at least:

https://store.tax.thomsonreuters.com/ac ... /100201392

I'll keep digging and see if I can find the electronic version.

JC
 


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