Maryland lawmakers are expected to revive a pair of failed controversial tax expansion proposals shortly after the scheduled start of the next legislative session on January 13, 2021. On May 7, Governor Larry Hogan vetoed...more
On September, 9, 2020, the New Jersey Appellate Division ruled against the taxpayer in Preserve II, Inc. v. Director, Div. of Taxation, No. A-1331-17T3. On its face, the decision looks like a disappointing taxpayer loss...more
On March 13, 2020, New York State Senator and Deputy Majority Leader Michael Gianaris (Democrat) introduced New York S.8056, which would establish a tax on a digital advertiser’s annual gross revenues derived from digital...more
The New York State Tax Appeals Tribunal held that a taxpayer was required, for years before 2015, to apportion its receipts based on the location of the work that generated its receipts, and not based on the location of its...more
8/9/2019
/ Administrative Law Judge (ALJ) ,
Data Repositories ,
Fee-for-Service ,
Gross Receipts ,
Income Apportionment ,
IP License ,
Market Based Approach ,
Sales Factor ,
Software ,
State Tax Tribunals ,
Tax Appeals ,
Tax Audits
On March 31, 2019, the New York Legislature approved budget legislation for the Fiscal Year 2020 (the “Budget Bill”). Among other things, the Budget Bill codifies the position of the New York State Department of Taxation and...more
New York State Governor Andrew Cuomo released his Fiscal Year 2020 budget and accompanying legislation on January 15, 2019 (the Budget Bill). Among other things, the Budget Bill proposes statutory revisions to respond to the...more
1/18/2019
/ Corporate Taxes ,
Dodd-Frank ,
Excise Tax ,
GILTI tax ,
Governor Cuomo ,
Marijuana ,
Online Sales Tax ,
Sales & Use Tax ,
Sales Tax ,
State Budgets ,
Tax Cuts and Jobs Act ,
Tax Exemptions
The New York State Department of Taxation and Finance released guidance in the form of tax return instructions addressing how it will account for global intangible low-taxed income (referred to as GILTI) for apportionment...more
On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible low-taxed income (GILTI) and...more
12/26/2018
/ Apportionment ,
Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Estate Tax ,
Foreign Derived Intangible Income (FDII) ,
GDP ,
GILTI tax ,
Governor Murphy ,
Internal Revenue Code (IRC) ,
State and Local Government ,
State Tax Equalization Boards ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Revenues
New Jersey launched its tax Amnesty program on November 15, 2018. The program runs through January 15, 2019. Here are the top things you need to know about the program...more
In a last-minute deal to avert a government shutdown, New Jersey Governor Phil Murphy and the New Jersey Legislature cobbled together a budget with numerous amendments to New Jersey’s tax law. Below is a summary of some of...more
On June 25, 2018, the New Jersey Legislature passed Assembly Bill 4262 (the Bill) to make several changes to the New Jersey corporation business tax (CBT). Governor Phil Murphy has indicated that he may veto the entire Bill...more
The New York Legislature passed its 2018-2019 Fiscal Year budget on March 30, 2018 (Budget), which is expected to be signed into law by Governor Cuomo. The starting point for determining New York taxable income is federal...more
The Pennsylvania Supreme Court held that the state’s flat $3 million cap on net operating loss (NOL) carryforwards violates the state constitution’s Uniformity Clause. Unlike the lower court, however, the Supreme Court left...more
In another taxpayer victory, the New Jersey Superior Court, Appellate Division held that an intangible holding company was not required to throw out any of its so-called “nowhere receipts” from an affiliated tobacco company...more