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Under Missouri law, sales are sourced for local tax purposes based on origin but, as a safeguard, no purchase made from an out-of-state seller may be subject to a higher tax burden than a similar purchase made from within a taxpayer's local jurisdiction.
The SPOCI portion is sourced under the general SPOCI rules and the remainder in accordance with Treas.
If a sale, the income would be sourced to the place where title to the property passes to the buyer.
Instead, it concluded that such fees should be sourced as if they were interest, even though they were not actually interest.