Home      Login

Rising Tide—Will Investment Managers Be Swept Up in State Income Tax Trends?  

Author:  Gregory A. Bergmann.; Keith Gray.; Karen Boucher.

Source: Volume 31, Number 04, Summer 2014 , pp.3-14(12)

Journal of Taxation of Investments

next article > |return to table of contents


More and more states are looking to increase state income tax revenues by expanding their definition of nexus beyond physical presence to include “economic activity” in the state. In addition, more states are moving from cost of performance to market-based sourcing for receipts from services and intangibles. The question thus arises: Do these new rules apply to investment funds and investment managers? If they do, the partners in the funds and fund managers may face new state tax liabilities as well as some sticky compliance and withholding rules. Copyright © 2014 Deloitte Development LLC. All rights reserved.

Keywords: nexus; market-based sourcing; economic nexus; investment manager; fund

Affiliations:  1: Deloitte Tax LLP; 2: Deloitte Tax LLP; 3: Deloitte Tax LLP.

Subscribers click here to open full text in PDF.
Non-subscribers click here to purchase this article. $15

next article > |return to table of contents