State and Local Taxation: Headline News and Trends (January 2015)
How the Rise in Undercover Investigations is Changing the Law
State and Local Taxation: Headline News and Trends (CPE/CLE)
Appel: Corporate Inversions Could Mean Big Tax Bills For Shareholders
Planning For The Exit – What’s Your Exit Strategy?
What Questions CEOs and Board Members Should Be Asking Themselves About Tax Inversions
Hodgson Russ's Tim Noonon on the Groundbreaking New York Residency Tax Case Gaied v. NYS Tax Appeals Tribunal
How to Avoid Corruption Risks in China
Private Equity's Inversion Excursion: Pepper Hamilton Talks Tax With the Deal
Polsinelli Podcasts - The Explosion of Tax Credits in 2014
Cross-Border Update on Investing and Doing Business in the United States
Tax Developments Affecting Health Care Organizations and Investor-Owned Hospital Companies
Did the IRS Just Help or Hurt the Bitcoin Economy?
Selling Privately Held Businesses – Interview with Stephen Gulotta, Managing Member, Mintz Levin's New York Office
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
Hot Topics for Waste-to-Energy Investors and Developers
Monitor Thy Drink: Alcohol Import Regulations Under the TTB (Alcohol and Tobacco Tax and Trade Bureau)
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate Insights
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
TAKE ACTION NOW TO AVOID UNEXPECTED STATE TAX LIABILITIES -
Traditionally, nexus for state income tax liability has required some type of physical presence or continuous contacts by the franchisor/distributor with a...more
I am often asked about franchisor liability under the Foreign Corrupt Practices Act (FCPA). Franchising has been a successful model in the US and now many corporations are looking at overseas expansion opportunities....more
In any merger or acquisition, parties incur costs beyond payment of the purchase price. Transaction costs can include compensatory payments (option cancellation payments, bonuses, etc.) and professional fees (legal,...more
Florida hotels and restaurants are facing license tax audits, assessments and penalties in increasing numbers. A "license" is statutorily defined as the granting of a privilege to use or occupy a building or real property....more
India recently staged the largest free democratic election in world history, bringing to power the National Democratic Alliance, led by the Bharatiya Janata Par ty, and with it a fresh sense of optimism about India’s economic...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.
Governor Rick Perry has signed into law Texas HB 500, which provides for certain changes to the Texas franchise tax provisions. ...more
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
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
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
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
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
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
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
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
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
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
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
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
In This Issue
2 SALT Pet of the Month; 5 Professor Hellerstein’s Office Hours; 9 California Screaming; and 9 Policy Wonk.
Sub Articles: A Swing and a Miss: Maryland Court Defines “Final” for Purposes of Statute of...more
Tennessee’s legislative session is in full swing, and based on the current pace of the session, legislators should finish their work during the first week of May, at the latest, and return to their districts for the November...more
Our final Alabama SALT Bulletin of 2011 summarizes the major legislative, judicial, and administrative developments affecting Alabama taxpayers with respect to income, transaction and property taxes. The Spring 2011...more
Table of Contents
II. General Nexus Standards ... 2
A. Registration To Do Business...2
B. Nexus For State Tax Purposes ... 3
1. Nexus for Texas Franchise Tax Purposes... 3
2. Leniency for...more
On May 27, 2011, The Texas Supreme Court found in favor of TGS-NOPEC Geophysical Company in a dispute involving how TGS' receipts from the licensing of its geophysical data should be apportioned for Texas franchise tax...more
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