The Florida Department of Revenue determined that a company providing television viewing data and analytics services must source its receipts from such services to the location of its customers, despite (1) the state’s majority costs of performance souring rule and (2) that the taxpayer appeared to incur the majority of its costs outside of the state. After questioning the policy wisdom of the costs of performance rule and reviewing two cases from other states, the Department adopted a narrow view of what constitutes the “income-producing activity.” The Department ultimately concluded that no costs of performance analysis was required because “[t]he income producing activity in the present case occurs wholly within Florida if the Taxpayer’s customer is located in Florida.” While the Department has issued a number of costs of performance rulings in the past several years, this ruling is particularly noteworthy for the depth of its analysis on the issue and its potential conversion of the regulatory costs of performance rule to a market sourcing rule in application. Fla. Dep’t of Revenue, TAA 13C1-011 (Nov. 21, 2013) (released Feb. 18, 2014).