Expedia: New York and Nationwide Implications

Overview


Arthur Rosen wrote this bylined article analyzing the New York state administrative law determination in Expedia, a dispute over how the company’s receipts should be sourced for corporate income tax apportionment purposes. Mr. Rosen wrote that the determination’s provisions “are important examples that show that a state’s audit initiative, even if used widely and for a long period, can be – and often should be – successfully challenged,” calling the state’s action “a sterling example of what is wrong with so many state tax audit programs throughout the country.”