Under previous law, the rentals, leases, and licensing of intangibles were allocated to Louisiana, not apportioned. Thus, these sales were thrown out of the Louisiana sales factor calculations. However, the throwout rule was irrelevant as allocable items are never included in the sales factor. For tax years beginning on or after January 1, 2024, the term rentals, leases, and licensing of intangibles was struck, leaving only the sales of intangibles subject to apportionment in Louisiana. These sales will be apportioned based on the market in which they are used. The enactment of Louisiana H.B. 631 repeals the state’s throwout rule for tangible property as well as intangible property.
Please reach out to Ryan tax professionals for guidance in implementing this change.
TECHNICAL INFORMATION CONTACTS:
Mark Nachbar
Principal
Ryan
630.515.0477
mark.nachbar@ryan.com
Robin Sigur
Director
Ryan
713.629.0090
robin.sigur@ryan.com
The material presented in this communication is intended to provide general information only and should solely be seen as broad guidance and not directed to the particular facts or circumstances of any individual who may read this publication. No liability is accepted for acts or omissions taken in reliance upon the content of this piece. Before taking (or not taking) any action, readers should seek professional advice specific to their situation from Ryan, LLC or other tax professionals. For additional information about this topic, please contact us at info@ryan.com.
- Topics
- Mark L. Nachbar
- Income Tax
- Louisiana