Florida issued guidance to a corporate income taxpayer on how it should source income from different services. A taxpayer must source sales of services to Florida if the income producing activity is performed in the state. “Income producing activity” means activity engaged in by the taxpayer for gains or profits. So, the most important factor in analyzing the income producing activity is the location of the customer. Florida advised the taxpayer to source its service income on a market basis to the location of the customer to which it provided the services.
Technical Assistance Advisement, No. 18C1-011, Florida Department of Revenue, September 27, 2018, released February 14, 2019, ¶206-420