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Checkfree – Another Taxpayer Win on New York State Online Service Receipt Sourcing; ALJ Determination Mirrors Expedia

New York taxpayers received additional guidance on the important issue of whether online services constitute “service” receipts, and how those receipts should be sourced, for New York corporate franchise tax purposes....more

New York Issues Two Advisory Opinions Regarding Surplus Lines Insurance

The New York State Department of Taxation and Finance (Department) issued two advisory opinions determining that unauthorized non-life insurance corporations (here, surplus lines insurance companies) are subject to insurance...more

New York State Division of Tax Appeals Addresses Unauthorized Insurance Company Taxation

A New York State Division of Tax Appeals administrative law judge (ALJ) issued three determinations addressing the tax implications for unauthorized insurance companies, both life and non-life. Significant uncertainty has...more

New York State ALJ Determines Travel Reservation Facilitation Receipts and Online Advertising Receipts Constitute Service Receipts...

There has been significant controversy in New York regarding whether receipts from services—particularly those that may be delivered via the Internet—constitute “service” receipts or “other business receipts” for corporate...more

MTC Launches Transfer Pricing Effort

On June 2, the Arm’s Length Advisory Group (the Group) of the Multistate Tax Commission (MTC) met in St. Louis, Missouri, to begin the process of developing a multistate arm’s length pricing adjustment service. States...more

MTC Executive Committee Advances Significant Part of UDITPA Rewrite

On Thursday, May 8, the Multistate Tax Commission’s (MTC) Executive Committee (Committee) met in Washington, DC. During the meeting the Committee voted to advance its amendments to the Multistate Tax Compact’s (Compact)...more

Legal Alert: New York Tax Reform to Impact Captive Insurance Companies

In January, New York Governor Andrew Cuomo proposed broad corporate tax reform in his budget bill, which is currently winding its way through the legislature. The most significant proposal is a shift from a separate entity...more

Massachusetts Governor Proposes Insurance Industry Pass-Through Tax

Massachusetts Governor Deval Patrick released his proposed FY 2015 budget on January 22, 2014. The proposed budget includes a tax provision that is targeted directly at the licensed insurance industry. Currently, income...more

Sutherland SALT Shaker: August 2013 Digest

In this issue: - No Expressions of Goodwill from Arizona Department of Revenue - California Court of Appeal: ITFA Doesn’t Make the CUT - Round We Go: Indiana Denies Taxpayer’s Intercompany “Residual...more

Sutherland SALT Shaker: July 2013 Digest

In this issue: - Arizona: Software Licenses Determined to Be Personal Property Rentals - Rent-a-Cloud: Arizona’s Transaction Privilege Tax Applies to Receipts from the Temporary Use of Online Software -...more

Sutherland SALT Shaker: May 2013 Digest

In this issue: - California FTB Takes Harley-Davidson for a Ride: Securitization Subsidiaries Are Financial Corporations with Nexus in California - “Tut-Tut,” Long Beach: California Supreme Court Permits...more

Sutherland SALT Shaker: April 2013 Digest

In this issue: - California Court of Appeal: No Man May Profit From His Own Wrongdoing in a Court of Justice - The (True) Object of My Affection: A Nontaxable Stock Screening Service - Alternate Universe...more

March 2013 - SALT Shaker Newsletter

In this issue: - Delivered by Independent Contractors, Undelivered by P.L. 86-272: Order Fulfillment Activities Subject Out-of-State Seller to New York Corporation Franchise Tax - Everything’s Bigger in Texas,...more

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