State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT) developments in several states which may be important to you.

Alabama

Debit Block Code to Change By January 31, 2024: The Alabama Department of Revenue (Department) recently published a Notice stating that if a taxpayer pays taxes through My Alabama Taxes using accounts that employ a debit block which requires an Originating Company ID (debit block code) to be approved for Automated Clearing House (ACH) debits, then the taxpayer must provide to the taxpayer's bank or financial institution an additional debit block code. The Department stated that this change is required because the Department is changing banks. While not all accounts will require this feature, the Department did state that if the taxpayer is unsure if the taxpayer's bank or financial institution account utilizes a debit block, then the taxpayer needs to contact them to verify. The Department then stated that the new Originating Company ID "MAT 6045055" must be added before January 31, 2024, to avoid interruption in processing future payments, but added that the taxpayer should not remove the current Originating Company ID "ADORCCD000" until after January 31, 2024, so that payments made before that date do not fail. The Department in the Notice also states that the Originating Company ID for local motor fuel taxes and non-state administrated local sales, use, rental, and lodging taxes filed through My Alabama Taxes/Single Point/ONE SPOT, will not change. Contact information is also included in this Notice for any questions. More information can be found here.

District of Columbia

Annual Tax Practitioner's Workshop on January 11, 2024: The Office of Tax and Revenue (OTR) recently published an announcement that the OTR will hold its annual "Tax Practitioner's Institute" on January 11, 2024, from 9 a.m. – 3 p.m. ET, and such seminar will take place online using the Teams platform. The OTR stated that the seminar is free, but registration is required using the registration link set forth in the announcement. According to the OTR, this seminar will provide tax preparers with a comprehensive presentation, with several speakers and an advanced look at what is new for the tax filing season and for the new tax year. The OTR notes that registered preparers during the week of January 8 will receive an email that will include a link to join the seminar. This announcement also includes a link through which questions can be submitted regarding the upcoming seminar. More information can be found here.

Florida

Multi-Tax Credits Available for Fiscal Year 2024-2025: The Florida Department of Revenue (Department) recently published Tax Information Publication No: 23ADM-05 addressing the allocation of multi-tax credits available for the State's fiscal year 2024-2025. According to this Publication, those multi-tax credits include the Live Local Program, the New Worlds Reading Initiative, the Strong Families Program, and the Florida Tax Credit Scholarship Program. The Publication also sets forth the credit caps associated with each of those Programs. The Department states in the Publication that the fastest and easiest way to apply for a tax credit allocation is online, and then provides in the Publication the links for the various Programs. Additionally, a webpage link is provided in the Publication for additional information regarding Tax Incentives for Businesses. More information can be found here.

Georgia

Proposed Amendment to Land Use Property Values for Easement Purposes: The Georgia Department of Revenue (Department) has recently published Notice LGSD-2023-003 regarding proposed Rules that would amend the tables of values used to calculate the land use values of property in conservation easements and used to calculate land use values of property in forest land protection easements. The Department stated in this Notice that its proposals are part of the annual update process which is necessary to allow county governments to prepare their tax digests. According to the Notice, the Department will consider the proposed amendments at a remote regulation hearing held at 11:00 a.m. on January 18, 2024, which can be accessed through the link set forth in that Notice or via telephone at the number set forth in that Notice. Attendees at that hearing, according to the Notice, will be required to announce themselves and notify the Department if they plan to make oral comments during the hearing. Further, the Notice states that all comments regarding the proposals must be received by the Department no later than 10:00 a.m. on January 18, 2024. More information can be found here.

Louisiana

Clarification of Disaster Extensions on the Automatic Filing Extensions: The Louisiana Department of Revenue (Department) recently issued Revenue Information Bulletin No. 23-029 which is intended to clarify the effects of disaster extensions on the automatic filing extensions granted for state individual income, fiduciary income, partnership income, and corporation income taxes. With respect to individual, fiduciary, and partnership income tax extensions, the Department states in this Bulletin that effective for tax years beginning on or after January 1, 2022, taxpayers are granted an automatic six-month extension of time to file these returns; and, for qualifying taxpayers with an extended date within a disaster extension period, the automatic extended due date to file is the final date of the disaster extension period or the automatic due date, whichever is later. With respect to taxpayers filing corporation income tax returns, the Department states in this Bulletin that for tax years beginning on or after January 1, 2022, taxpayers are granted an automatic extension to file the corporation income tax return if the taxpayer timely requests an extension of time to file the federal corporation income tax return for the same taxable period; and in such case, the extension is six months or to the extended due date of the federal return, whichever is later. Examples are given in the Bulletin with respect to the extension for individual, fiduciary, partnership and corporation income tax extensions. With respect to corporation franchise tax extensions, the Department states in the Bulletin that corporation income tax extensions apply to taxpayers filing a corporation franchise tax return in conjunction with the corporation income tax return. However, as to taxpayers filing a franchise tax-only return with an original due date within the disaster extension period, the Department states in the Bulletin that the extended due date will be the original due date or the final date of the disaster extension period, whichever is later. Contact information is set forth in this Bulletin for questions pertaining to extensions. More information can be found here.

Maryland

Guidance as to Private Letter Rulings: Effective December 22, 2023, the Comptroller of Maryland (Comptroller) issued Technical Bulletin No. 44 which is entitled "Private Letter Rulings" and which is intended to provide guidance and procedures for submitting a petition for a private letter ruling. The Comptroller in this Bulletin states that private letter rulings are a formal type of guidance issued by the Comptroller to a specific taxpayer, and they are intended to address complex or novel questions applying to a specific prospective transaction. The Comptroller then states that a petition must comply with the requirements described in this Bulletin, which then sets forth general definitions and other information regarding private letter rulings such as information involving the submission of a petition, the denial and withdrawal of a petition, requests for additional information regarding the petition, among other topics involved with seeking a private letter ruling. The Bulletin also sets forth some Q&As pertaining to a private letter ruling and provides contact information for the Comptroller's Legal Division in the event of questions. More information can be found here.

Mississippi

2024 Charitable Contribution Credits FAQs: The process for applying for Charitable Contribution Tax Credits will be different from prior years. The Mississippi Department of Revenue (Department) recently issued Frequently Asked Questions for the 2024 charitable contribution credits. These FAQs cover a wide variety of topics including: when will the Taxpayer Access Point online application be available; when will the application screen time out; will the Department confirm receipt of the application; and how long the donor has to donate. These and other questions regarding the 2024 charitable contribution credits are addressed here.

North Carolina

Interest Rates Increased for 2024: The North Carolina Department of Revenue (Department) recently announced that the interest rate from January 1, 2024, through June 30, 2024, will be eight percent, which is an increase from the seven percent rate that was applicable from July 1, 2023, through December 31, 2023. The Department noted that interest rates shown in that announcement do not apply to the International Fuel Tax Agreement (IFTA). In a separate announcement, the Department set the interest rate for IFTA at ten percent for the period from January 1, 2024, through December 31, 2024, an increase from the eight percent that was applicable for the period from January 1, 2023, through December 31, 2023. More information can be found here and here.

South Carolina

Change In Mandatory Minimum W-2 Upload Requirement: The South Carolina Department of Revenue (Department) recently issued a News Release advising that, in keeping with new IRS requirements, employers who file at least 10 W-2 or 1099 forms with the Social Security Administration must submit those forms to the Department using MyDORWAY. The Department noted in this Release that previously only employers with 250 or more W-2s were required to upload those forms electronically to the Department. Further, the Department stated that employers can now upload the W-2 C, W-2 G, and some types of 1099s on MyDORWAY. More information regarding these new requirements can be found here.

Tennessee

Utilization of Tax Credits Against Future F&E Tax Liabilities Following Merger: The Tennessee Department of Revenue (Department) recently posted Letter Ruling #23-09 addressing the question of whether a corporation could continue to utilize unused carryover credits against franchise and excise tax liabilities after the merger with its single member limited liability company that generated the credits. The corporate taxpayer in this Ruling was headquartered outside of Tennessee, but either directly or through wholly owned subsidiaries and disregarded entities, maintained facilities in Tennessee. In that regard, the corporate taxpayer wholly owned a single-member limited company that operated a Tennessee facility, and for all periods relevant to this Ruling the Single-Member LLC (SMLLC) was disregarded both for federal tax purposes and Tennessee franchise and excise tax purposes. That SMLLC made capital investments in industrial machinery placed into service in Tennessee and created new jobs at the Tennessee facility; and, as a result of the foregoing, industrial machinery tax credits, job tax credits, and additional annual job tax credits were claimed by the corporate taxpayer on its franchise and excise tax returns. For various business reasons, the corporate taxpayer has considered merging the SMLLC into the corporate taxpayer with the corporate taxpayer being the survivor of that merger. The Ruling noted that apart from the fact that the Tennessee facility would be owned and operated directly by the corporate taxpayer following the merger, there would be no changes anticipated in the Tennessee facility and the assets that gave rise to the credits would remain with the Tennessee facility. In response to the question raised, the Department noted that while no tax credit incurred by a predecessor taxpayer shall be allowed as a credit on the tax return filed by the successor taxpayer, the corporate taxpayer in this situation is not a successor entity to the SMLLC. Rather, the corporate taxpayer is the corporate single member of the SMLLC that was disregarded both for federal income tax purposes and franchise and excise tax purposes; and, accordingly, the activities of the SMLLC are considered the activities of the taxpayer. As such, the Department concluded in the Ruling that the corporate taxpayer may continue to utilize the credits after the merger with SMLLC. More information can be found here.

Texas

Penalty and Interest Chart Through September 2024: The Property Tax Assistance Division of the Comptroller's Office (Comptroller) recently issued a chart setting forth the penalty and interest to be used in calculating the amount due on delinquent property tax bills. The chart applies to delinquent tax payments in the months of October 2023 through September 2024. Instructions for using the chart are included within. More information can be found here.