In Spotlight on Tennessee: Letter Ruling Addresses Treatment of a Section 338(h)(10) Election, dated July 10, 2014, we examined how Tennessee treats the federal election under Internal Revenue Code Section 338(h)(10) for...more
During the 108th General Assembly 2014 Session, the Tennessee Legislature considered several tax and related initiatives before adjourning in late April. Although the number of proposed tax and related initiatives this...more
Tennessee does not expressly conform to most provisions in Subchapter C of the Internal Revenue Code. Instead, Tennessee's federal corporate income tax conformity is determined based on the "starting point" that Tennessee...more
For Tennessee excise and franchise tax purposes, a taxpayer that has business activities taxable both inside and outside this state must apportion its business net earnings and net worth using a three-factor apportionment...more
In November, the Tennessee Department of Revenue (Department) issued two notices to help clarify Franchise and Excise Tax classification of single member LLCs (SMLLCs) and series LLCs.