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https://www.thetaxadviser.com/issues/2016/sep/rethinking-scope-of-delivery-under-pl-86-272.html
It has been suggested that the term "delivery" for purposes of P.L. 86-272 protection should be subject to the same standard as was established in Wrigley, 505 U.S. 214 (1992), for "solicitation." Specifically, delivery - related activities that have no business purpose outside of the delivery of orders should be protected from state taxation.
https://www.taxops.com/interpreting-public-law-86-272-in-california/
Dec 11, 2019 · California’s Technical Advice Memorandum: 2018-03 addresses the application and interpretation of Public Law 86-272 in the context of delivering goods by company owned delivery vehicles. This memorandum concluded the delivery via a private delivery truck is protected activity under Public Law 86-272.
http://news.cchgroup.com/2018/12/19/california-addresses-p-l-86-272-protection-for-company-vehicle-deliveries/news/state-tax-headlines/
Dec 19, 2018 · California concluded that P.L. 86-272 protects the delivery of goods by company owned vehicles. But, it does not protect any activity that goes beyond the scope of delivery, like backhauling. Technical Advice Memorandum 2018-03 , California Franchise Tax Board, December 4, 2018, ¶406-876
https://www.stateandlocaltax.com/california/podcast-p-l-86-272-protection-deliveries/
Jan 31, 2019 · Podcast: P.L. 86-272 Protection for Deliveries. By Eversheds Sutherland SALT on January 31, 2019. Posted in California, Income, Podcast. In this podcast, Eversheds Sutherland state and local tax attorney Chris Lee discusses California Technical Advice Memorandum 2018-3 and the application of P.L. 86-272 to deliveries by private trucks.
http://www.mtc.gov/getattachment/Uniformity/Project-Teams/P-L-86-272-Statement-of-Information-Work-Group/What-to-Do-With-Public-Law-86-272.pdf.aspx?lang=en-US
personal property may conduct two activities in a state while retaining P.L. 86-272 protection: solicitation and delivery. The seminal case regarding P.L. 86-272, Wisconsin Department of Revenue v. William Wrigley Jr. Co ., helped shed light on the permissible extent of these activities. Importantly,
https://www.stateandlocaltax.com/new-york/delivered-by-independent-contractors-undelivered-by-pl-86-272-order-fulfillment-activities-subject-o/
Mar 27, 2013 · Delivered by Independent Contractors, Undelivered by P.L. 86-272: Order Fulfillment Activities Subject Out-of-State Seller to New York Corporation Franchise Tax. Posted on March 27, 2013. Posted in New York, Noteworthy Cases. By Sahang-Hee Hahn and Prentiss Willson.
https://www.ftb.ca.gov/about-ftb/newsroom/tax-news/december-2019/all-about-business.html
Technical Advice Memorandum: 2018-03 addresses the application and interpretation of Public Law 86-272 in the context of delivering goods by company owned delivery vehicles. This memorandum concluded the delivery via a private delivery truck is protected activity under Public Law 86-272.
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