On January 5, the Texas Comptroller of Public Accounts filed proposed amendments to 34 Tex. Admin. Code §3.591 with the Secretary of State in response to the Texas Supreme Court’s unanimous decision in Sirius XM Radio Inc. v. Hegar. On March 14, it formally adopted those amendments. Background By statute, Texas applies a traditional performance-oriented sourcing method for gross receipts from sales of services for the sales factor of the Texas franchise tax apportionment formula.
