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Implementing Recent MTC Guidelines: PL 86-272 and the Finnigan Method

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, October 26, 2023

Recorded event now available

or call 1-800-926-7926

This webinar will address the recent guidelines issued by the Multistate Tax Commission (MTC) concerning the application of PL 86-272 in today's virtual business environment. Our panel will analyze the new standards and review other current MTC recommendations.


Simply put, PL 86-272 prevents states from imposing an income tax on a business when its only connection with the state is the solicitation of orders of tangible personal property. Many companies have continued to rely on PL 86-272 to shield them from state income tax liability. Enacted in 1959, this statute did not foresee the internet and digital commerce. On Aug. 4, 2021, the MTC adopted updates to its prior statement on PL 86-272 that incorporate e-commerce and provided examples of specific activities that constitute doing business in a state.

These activities include:

  • Transmitting code or electronic instructions via the internet to fix or upgrade products
  • Providing post-sale assistance to in-state customers via chat or email
  • Placing internet "cookies" onto the computers or other electronic devices of in-state customers

As states enact new recommendations, multistate businesses and SALT practitioners need to understand the reach and implementation of the new guidelines.

Listen as our panel of SALT experts reviews new PL 86-272 guidance issued by the MTC, offers recommendations for implementing the latest standards, and reviews other recent MTC recommendations for businesses operating in multiple states.



  1. The Multistate Tax Commission
  2. PL 86-272 background
  3. MTC's Statement on PL 86-272
  4. MTC's Model Statute for Combined Reporting: the "Finnigan Method"
  5. Other recent guidelines


The panel will cover these and other key issues:

  • The purpose and mission of the MTC
  • Internet activity that creates state income tax nexus under MTC's August 2021 guidelines
  • MTC's recent statement on combined reporting a/k/a the Finnigan Method
  • Tips for businesses transitioning to the new guidelines


Roberts, Stacey
Stacey L. Roberts, CPA

State and Local Tax Director

Ms. Roberts has been making state and local tax (SALT) less taxing for thousands of businesses over the last 25 years....  |  Read More

Smith, Meredith
Meredith Smith, CPA

Senior Tax Manager

Ms. Smith expertly weaves real-life examples into why business taxpayers, tax professionals, and tax providers should...  |  Read More

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