Clarification on benefits received in Michigan

If you ever found yourself wondering how to interpret the “benefit received” test for sourcing service revenue, Michigan has heard your frustration.  The Michigan Department of Treasury recently released Revenue Administrative Bulletin 2015-20, which provides some much needed context to the application of the benefit received test for purposes of sourcing service receipts as part of the sales factor of the apportionment formula.  The Bulletin sets guidelines for situations when all the benefit of a service might be received in Michigan, and for situations when the recipient of the service receives only a portion of the benefit of the service in Michigan.  The Bulletin also provides specific examples, and expands on certain situations which may not be covered by the general guidelines. 

 

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