News & Analysis as of

Corporate Taxes Income Apportionment

Foster Garvey PC

The Changing Face of Employer State Tax Reporting and Payment Obligations in the Coronavirus Telework "New Normal"

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In the wake of the coronavirus pandemic, companies in wide-ranging industries across the country have unprecedented numbers of employees working from remote locations. In a prior post, we discussed numerous issues that may...more

Holland & Hart LLP

Taxpayer Victory in Utah Income Tax Single Sales Factor Case

Holland & Hart LLP on

The Utah Tax Commission recently ruled in favor of a taxpayer in Case No. 16-155 by authorizing the taxpayer to use a single sales factor for Utah corporate franchise tax... Under Utah law, taxpayers in certain NAICS Codes...more

Eversheds Sutherland (US) LLP

Maryland enacts legislation adopting single sales factor apportionment

On April 24, Maryland Governor Larry Hogan signed Senate Bill 1090 and House Bill 1794 (collectively, the Bills), which adds Maryland to the growing list of states that are moving towards a single sales factor formula to...more

Smith Anderson

Senate Bill 628 Update

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Two previous Tax Alerts, Tax Provisions in the 2017 Budget Bill (June 20, 2017) and Tax Legislation Enacted During the Regular Session of the 2017 North Carolina General Assembly (June 30, 2017), summarized the major tax...more

Troutman Pepper

California FTB Provides Guidance on Certain Section 382 Calculations - Tax Update Volume 2017, Issue 3

Troutman Pepper on

California requires taxpayers that have income within and outside the state to "apportion" their overall income between the two categories based upon certain factors and rules for determining their California tax liability....more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 7

ALJ holds NYS Real Estate Transfer Tax Cannot Be Imposed on Sale of 45% Membership Interest in LLC - In an issue of first impression under the New York State real estate transfer tax, a New York State Administrative Law...more

Bradley Arant Boult Cummings LLP

Comments on Proposed New Alabama Corporate Income Tax Apportionment Rules

The Alabama Department of Revenue (ADOR) recently proposed numerous changes to its apportionment rules for corporate income taxpayers, with the stated intention of adopting “recommended amendments to the [Multistate Tax...more

Miller Canfield

Michigan Court of Appeal finds Multistate Tax Compact applicable to the former Michigan Single Business Tax (SBT) Act

Miller Canfield on

On February 25, 2016, the Michigan Court of Appeals released a decision for publication in the consolidated case of AK Steel Holding Corporation v. Department of Treasury, which upholds the ability of taxpayers to make the...more

Smith Anderson

North Carolina Moves Towards Single Sales Factor and Market Sourcing

Smith Anderson on

An earlier Tax Alert discussed the possibility that North Carolina would adopt the single sales factor method of apportioning the business income of multi-state corporations. During the current legislative session, single...more

Stoel Rives LLP

Tax Law Alert: Sales Factor Excludes Amounts Received from the Sale of Goodwill

Stoel Rives LLP on

In a case argued by Stoel Rives, the Oregon Supreme Court upheld the judgment of the Oregon Tax Court in favor of Tektronix, Inc. The Supreme Court ruled that, for purposes of apportioning income, the sales factor excluded...more

Morrison & Foerster LLP

Q&A With Morrison & Foerster's Mitch Newmark

Mitchell A. Newmark is a partner at Morrison & Foerster LLP and is concentrated on state and local tax litigation and appeals before administrative and judicial bodies around the country. Newmark also advises companies and...more

Baker Donelson

Spotlight on SALT: Income Apportionment and the Multistate Tax Compact's "Taxpayer Option" – Uncertainty for Corporate Taxpayers...

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A state's corporate tax income apportionment formula is at the heart of determining a business's multistate income tax liability....more

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