The 2015 Legislative Session, 109th General Assembly, considered a large number of tax and related initiatives. Many of these initiatives have been enacted, some with very far reaching impact upon the tax climate in this...more
Governor Haslam's Administration has very recently proposed far-reaching amendments to Tennessee's tax laws. These proposed amendments are included in Senate Bill 603/House Bill 644, known as the Revenue Modernization Act...more
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.