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
In Private Letter Ruling 201420004 (released May 16, 2014), the Internal Revenue Service (IRS) has ruled on the question of which party in a contract manufacturing arrangement is the "manufacturer" for purposes of the medical...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
Two recent letter rulings issued by the Tennessee Department of Revenue (Department) and posted on January 22, 2014 illustrate that nothing should be taken for granted in the sales and transactions taxes area when services...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.
Believe it or not, Uncle Sam provides help to exporters on the tax front. The help is in the form of a valuable export tax incentive known as a Domestic International Sales Corporation, or "DISC."...more
Hotels stock rooms with soaps, shampoos, conditioners, mouthwashes, shower caps, pens, notepads and similar non-reusable consumable items (hotel consumables) for the use of hotel guests. Guests are free to use the items, not...more