Tax Franchise

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Spotlight on Tennessee: DOR Clarifies Franchise and Excise Tax Classification of SMLLCs and Series LLCs

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. ...more

2013 Texas Legislative Session Review

THE CURRENT ERA OF AMERICAN POLITICS IS OFTEN LAMENTED AS EXCESSIVELY PARTISAN, IDEOLOGICAL, AND RANCOROUS. And Texas politics has often held its own in those regards. But to many observers, the recently completed 2013 Texas...more

Case Law – Hotel Regulations – States or Federal Government Authority

In this Issue:- 1. Legal Alert – Case Law – Hotel Regulations – States or Federal Government Authority 2. Disclaimer Notice. 3. Copyright Notice. Introduction On the 9th day of July 2013, the Supreme Court of...more

Fast Food Comes to Indian Country

In-N-Out Burger, the quintessentially Californian burger chain, will open its first restaurant on tribal land in early 2014 at the Morongo Casino on the Morongo Indian Reservation on the heavily trafficked Interstate 10. The...more

Texas enacts taxpayer-friendly revisions to franchise tax

Governor Rick Perry has signed into law Texas HB 500, which provides for certain changes to the Texas franchise tax provisions. ...more

News and Insights from Austin - Q2 2013

Welcome to the summer issue of News and Insights. In this issue, I’m proud to highlight Becca McKnight, who was recently selected by The Food and Drug Law Institute (FDLI) to serve on its Medical Devices Committee. Becca...more

PA Capital Stock/Franchise Tax Phase-out Deferred; Related Party Addback Enacted; Numerous Other Tax and Credit Changes Made

On June 30th Governor Corbett signed a $28.4 billion state appropriations package which provides modest increases in some areas and flat funding in others. Although the popular press suggested that the budget included no...more

Major PA Tax Bill Passes: Franchise Tax is Back! Market Sourcing has Arrived; Addbacks Too

After months of negotiations and bargaining surrounding Pennsylvania’s budget, the House and Senate passed major tax code changes Tuesday (in House Bill 465). The bill is now on its way to Governor Corbett’s desk for...more

Sutherland SALT Shaker: May 2013 Digest

In this issue: - California FTB Takes Harley-Davidson for a Ride: Securitization Subsidiaries Are Financial Corporations with Nexus in California - “Tut-Tut,” Long Beach: California Supreme Court Permits...more

New Mexico 2013 Tax Legislation Update

The recently concluded 2013 regular session of the New Mexico Legislature resulted in legislation enacting several significant changes to New Mexico’s tax programs, the majority of which are business friendly. Most of the...more

Navigating Pennsylvania’s Tax Appeals Process -- Updated

Pennsylvania’s tax appeal system has long been criticized as very complicated, expensive and lacking impartiality. A few years ago, the PA Chamber and other interested groups were able to work with the General Assembly to...more

Franchising in Spain: 2012 in Review

With Madrid's annual franchise fair just around the corner, now is a good time to analyze what 2012 was like for the franchise sector in Spain. A solid performance overall, especially strong for Spanish franchises abroad....more

Recent Developments in New York's Taxation of Unauthorized Life Insurers

Prior to 2012, New York afforded surprisingly favorable tax treatment to life insurance companies that are not licensed to conduct business in New York ("unauthorized life insurers"), but that owned real estate investments in...more

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

Legal Alert: A Royal Opportunity: Amendments to New York’s Royalty Expense Add-back Statute Leave the Income Exclusion Intact for...

On March 28, 2013, the New York State Legislature passed budget legislation (S.2609D/A.3009D) that replaces the existing New York State and City related - party royalty add - back requirements with provisions based on the...more

Attorney General Prevails In Lawsuit Against Income Tax Preparation Company

The Attorney General brought a lawsuit against an income tax preparation business alleging violations of state and federal lending, consumer protection, unfair competition, and false advertising laws. The court of appeal...more

Franchisors: Don’t Forget To File Your New York Annual Sales Tax Information Report

All franchisors that have at least one franchisee operating in New York State should be aware that they must file an annual information return next month under a state tax law. This annual report is due on or before March...more

Alabama Tax Developments: 2012 Year in Review

Our final Alabama SALT Bulletin of 2012 summarizes the major legislative, judicial, and administrative developments affecting Alabama taxpayers with respect to income, transaction, and property taxes. The spring 2012...more

2013 Audit Guidelines For Small Business

What three letters strike fear into the heart of small business owners across the United States? I . . . R . . . S Internal . . . Revenue . . . Service. And in 2013 there may be even greater reason for small...more

Focused on Franchise Law - November 2012

In This Issue: - Barry Kurtz Honored As Trusted Advisor - Franchisor 101: It's That Time Again: Renewal Season 2013! - Franchisee 101: Reporting Sales and Paying Taxes-A Double Edged Sword - Barry Kurtz...more

Focused on Franchise Law - August 2012

In This Issue: - Barry Kurtz Honored As Trusted Advisor - Franchisor 101: Exploring Exemptions Under California's Franchise Investment Law - Part 1 - Franchisee 101: Taxes, 2013 and Selling Your Franchise...more

Supply Chain Efficiency: Valuation and Transfer Pricing Considerations

Deriving maximum cost efficiency from the supply chain is a critical operational issue for multinational enterprises (MNEs) in certain regions. As taxation is typically one of a group’s largest costs, supply chain...more

MoFo New York Tax Insights - Volume 3, Issue 6 - June 2012

In This Issue: ALJ Holds New Resident’s Gain on Sale of Former Connecticut Home is Subject to New York Income Tax; Tribunal Reinstates Peter Madoff Petition; Banking Department’s Definition of “Gross Income” Not Properly...more

Where’s the “Beef”? Sublicensing Qualifies for Virginia Addback Exception

On March 29, 2012, the Circuit Court of the City of Richmond held that an exception to Virginia’s related party addback statute applied to licensing arrangements that included a sublicensor. Wendy’s International, Inc. v....more

Where’s the Beef? Virginia Circuit Court Allows Wendy’s to Claim Exception to Addback for Royalties Paid to Affiliate

A new opportunity may exist for franchisors to claim an exception to Virginia’s royalty addback statute based on a recent Circuit Court decision. In Wendy's International Inc. v. Virginia Dep't of Taxation, decided March...more

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