Madison Barnett

Madison Barnett

Sutherland Asbill & Brennan LLP

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Here’s the Deal: Georgia Governor Signs Several Significant Tax Bills

Following the conclusion of Georgia’s 2016 legislative session, Governor Nathan Deal signed into law several tax bills touching on a wide range of tax matters, including sales and use taxes, property taxes, corporate income...more

5/11/2016 - Audits Corporate Taxes E-Commerce Governor Deal Interest Rates New Legislation Property Tax Sales & Use Tax State Tax Tribunals State Taxes Tax Credits Tax Exemptions

State Tax Fallout From Federal Proposed Related-Party Debt Regulations

Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more

4/26/2016 - Add-Back Legislation Consolidated Tax Returns Debt Foreign Affiliates Franchise Taxes Income Taxes Intercompany Transactions Internal Revenue Code (IRC) IRS Proposed Regulation Related Parties State Taxes Tax Deductions U.S. Treasury

Bad Day for California as TTA Sales Tax Exemption for Software Is Broadly Reaffirmed by Appellate Court – Will Taxpayer Refund...

In a significant rebuff of the California State Board of Equalization (BOE), the California Second District Court of Appeal held that a manufacturer’s sale of software on tangible media was exempt from sales tax under the...more

10/13/2015 - Appeals CBOE Copyright IP Assignment Agreements IP License manuf Patents Sales & Use Tax Software Tangible Property Tax Exemptions Technology Transfer Agreements

Georgia Supreme Court Rejects Challenge to Property Tax Incentives

On March 27, 2015, the Georgia Supreme Court rejected a challenge to the legal validity of property tax incentives in Georgia, largely on procedural grounds. SJN Properties, LLC v. Fulton County Bd. of Tax Assessors, No....more

4/2/2015 - Economic Development GA Supreme Court Property Tax Standing Tax Incentives

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

6/3/2014 - Audits Multistate Tax Compact Transfer Pricing

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

5/12/2014 - MTC Multistate Tax Compact Proposed Amendments UDITPA

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

2/28/2014 - Andrew Cuomo Captive Insurance Company Corporate Taxes State Taxes Tax Reform

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

5/1/2013 - Apportionment Bundling Rules Dividends Equal Protection Equity Compensation Foreclosure Income Taxes Net Investment Income Partnerships Premises Liability Refunds Sales & Use Tax Stocks Voluntary Disclosure Agreement

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

4/1/2013 - Burden of Proof Business Income Double Taxation Excise Tax Independent Contractors Joint and Several Liability Sales & Use Tax Tax Assessment

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