The Commonwealth Court of Pennsylvania held that an exemption to the application of PA Realty Transfer Tax Section (RTT) for no or nominal consideration from a trust under Section 1102-C.3(9.1)1 applies not only to transfers...more
Effective November 4, 2023, the New Jersey Business Corporation Act (the Act) will be amended to permit conversions and domestications across all business entity types, including foreign and domestic corporations. The delay...more
Tax season is well underway, and after a tumultuous year in 2020, businesses may be looking to save money any way they can. Last year presented a different, though equally difficult, set of challenges for state and local...more
As we noted in our previous SALT Alert, on October 1 the Alabama Department of Revenue (ADOR) quietly posted a notice on its website and shared it with media outlets that received little notoriety – at least initially. The...more
In a case of first impression by an Alabama appellate court, the Alabama Court of Civil Appeals recently considered the appeal of the Alabama Department of Revenue (ADOR) of an adverse circuit court ruling involving whether...more
If a corporation or LLC stops doing business in a state in which it was registered to do business as a “foreign” company, just walking away does not end its responsibilities in that state. State statutes apply different terms...more
On August 28, 2017 the South Carolina Department of Revenue published Rev Rule #17-5, which updated Rev Rule #15-3 (the “Rev Rul”). The Rev Rul deals with the application of the deed recording fee on real estate...more
In a ruling from September 6, the Alabama Tax Tribunal distinguished the scope of the federal and the Alabama responsible person penalty, holding the Alabama penalty did not apply to a mere employee. In Ty P. Taylor v. State...more
The ADOR has proposed a number of amendments to its rule governing the filing of partnership tax returns, Form 65. The new rule, as proposed, inserts language conforming with Alabama’s recently enacted “factor presence nexus”...more
It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more
The Tennessee Department of Revenue has issued Notice 13-06 to clarify the tax treatment of single-member limited liability companies (SMLLCs) owned by entities checking the box to be treated as corporations for federal tax...more