In a case where the MTC had filed an amicus brief supporting the Massachusetts Department of Revenue, the Massachusetts Supreme Judicial Court has found in favor of the Department. The case concerned the proper application of MTC model apportionment rules for financial institutions. A subsidiary of a financial institution that had no employees and contracted to do loan servicing with third parties argued the loans should be sourced to the location of those third parties. The court rejected this argument, agreeing instead with the revenue department that the state where the parent company was domiciled was the proper location to attribute the loans for apportionment purposes.
You can read the Commission’s brief below.
