Humana Pharmacy Unit’s Income Taxable in Minnesota, Justices Say

Humana Inc. failed to convince the Minnesota Supreme Court on Wednesday that pharmacy benefits management services one subsidiary provided to another aren’t taxable in the state because they were received in Wisconsin.

The meaning of “received” in the state’s services sourcing statute “is not limited to receipt by a taxpayer’s direct customer,” Justice Karl C. Procaccini wrote for the unanimous court. Humana needed to prove that all of its services were received outside of Minnesota to be entitled to summary judgment, but undisputed facts show that both insurance plan members in Minnesota and the plan itself in Wisconsin received its ...