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Administrative Law Judge (ALJ) Tax Liability

Blank Rome LLP

New York ALJ Rejects Division of Taxation’s Attempt to Change Its Theory of Liability after the Hearing

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A New York State Administrative Law Judge (“ALJ”) recently rejected an attempt by the Division of Taxation (“Division”) to change its theory of liability after the record was closed, raising its new theory of liability for...more

Pillsbury - SeeSalt Blog

New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operating Location

The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the...more

Freeman Law

Texas Tax Roundup | April 2023: Pleas to the Jurisdiction, Retail and Wholesale Franchise Tax Rate, and More

Freeman Law on

Howdy folks, and welcome back to another edition of the Texas Tax Roundup, where we gab about all things Texas tax and perhaps even some things Texas tax adjacent. As ole T.S. once put it, “April is the cruelest...more

Freeman Law

Texas Tax Roundup | November 2022: What’s a Franchise Tax?

Freeman Law on

Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more

Freeman Law

Texas Tax Roundup | August 2022

Freeman Law on

Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more

Rivkin Radler LLP

New York to Taxpayer: “Forget What the Feds Said, You’re a ‘Responsible Person"

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Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more

Freeman Law

Texas Tax Roundup | February 2022 (RECOVERED!)

Freeman Law on

Howdy y’all!  Has it been a month already?  We’ve got another action-packed month of Comptroller-related news.  Here we go! Court Cases Courts of Appeals Hegar v. Black, Mann, and Graham, L.L.P., No. 03-20-00391-CV (Tex....more

Rivkin Radler LLP

Will New York Be Looking At Your Federal Tax Return? Probably

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State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more

Akerman LLP - SALT Insights

New York Broadly Applies Information Service Tax to Marketing Analytic Services

A year and a half following the New York Court of Appeals’ significant 2019 decision in Matter of Wegmans Food Markets, Inc. v. Tax Appeals Tribunal of State of New York, 33 NY3d 587 (2019), New York continues to grapple with...more

Farrell Fritz, P.C.

Continuing Economic Distress: Withholding Taxes And The Risk Of “Self-Help”

Farrell Fritz, P.C. on

Stimulus Legislation Limbo- In has been 192 days since the President declared a national emergency concerning the COVID-19 outbreak. Across the country, businesses and communities were immediately placed on lockdown[ii] in...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

Burr & Forman on

There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Troutman Pepper

ALJ Forces Combination of Hedge Fund Group in New York City - Tax Update Volume 2017, Issue 4

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On April 27, the New York City Tax Appeals Tribunal issued a decision requiring the related members of a hedge fund group to file a combined return for New York City tax purposes. However, the administrative law judge (ALJ)...more

Troutman Pepper

New York State Denies Taxpayer's Insurance (Deduction) Claim - Tax Update Volume 2016, Issue 1

Troutman Pepper on

Captive insurance arrangements, in New York and in certain other states, are often dependent on the federal treatment of the relationship as insurance for federal income tax purposes. A recent New York state...more

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