Manufacturing, as often noted, is the backbone of the American economy. Manufacturers not only innovate and create products that contribute to the betterment of our way of life but are also critically fundamental to our...more
The Minnesota Supreme Court has held that market research conducted by an out-of-state company’s sales representatives when visiting in Minnesota exceeded “solicitation of orders” and therefore, the company was not protected...more
If you own a business in Texas, you’ve likely encountered (for better or worse) the Texas franchise tax. The franchise tax is a tax imposed on any “taxable entity” that does business in Texas or that is chartered or...more
This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
This Alert summarizes all the material amendments to Chapter 105 of the North Carolina General Statutes ratified to date during the General Assembly’s 2024 short session....more
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)...more
It is not uncommon for Texas taxpayers to engage in a transaction in which they do not collect or pay Texas sales tax, believing the transaction to be nontaxable, only to later find out they had a tax responsibility. Other...more
Always forgetting to file your Texas Franchise Tax Reports on time? Starting in 2024, you might find yourself exempt from this task. ...more
This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
Gov. Bill Lee recently signed into law Public Chapter 950, which creates significant changes in how Tennessee's franchise tax is calculated. Until now, the franchise tax has been calculated based on 1) a taxpayer's...more
The Illinois Franchise Tax (the “Franchise Tax”) is an extremely complex tax that places unique burdens on corporations conducting business in Illinois. Based on our experience, many corporations incorrectly calculate their...more
Understanding the Franchise Tax requires an understanding of four critical terms used throughout its computing and filing process. These terms are: Paid-In Capital, Taxable Year, Fiscal Year, and Allocation Factor. While some...more
The importance of calculating your Franchise Tax Allocation Factor cannot be understated. Improper calculation of this factor can lead to over and underpayment of Franchise Tax, triggering penalties, interest accrual, and the...more
This series of articles is intended to provide a deep dive into the Illinois State Franchise Tax (the “Franchise Tax”) and should be read sequentially to be best understood. The first article covered the businesses and...more
Commissioner of the Tennessee Department of Revenue (Department), David Gerregano, recently testified before the Revenue Subcommittee of the Senate Finance, Ways and Means Committee, regarding the Department's proposed...more
The Tennessee Department of Revenue (Department) recently posted certain selected informal conference summaries which provides taxpayers with insight into how the Hearing Office will address various issues arising under...more
On December 27, 2023, the New York State Department of Taxation and Finance (Department) officially adopted the business corporation franchise tax regulations it submitted to the State Register on August 9, 2023 – marking the...more
The Ohio Board of Tax Appeals held that a manufacturer that delivered its products to a distribution center/warehouse in Ohio successfully demonstrated that a large percentage of those products were subsequently shipped...more
An investment management company subject to California corporate franchise tax was required to source its receipts from the provision of management, administrative, and distribution services furnished to mutual funds based on...more
An Administrative Law Judge (“ALJ”) at the State Division of Tax Appeals sustained two deficiency notices assessing over $15 million in tax against Cushlin Limited (“Cushlin”), a business that acquires and refurbishes hotels....more
On August 9, 2023, the New York State Department of Taxation and Finance (Department) submitted its draft corporate franchise tax regulations for publication in the State Register – a significant and necessary step in the...more
Welcome back to another hard-hitting edition of Texas Tax Roundup. Let’s see what the Texas tax world weathered the scorching month that was June 2023: Court Cases - Protest Payments - L.L.C., Inc. and Fun...more
Hiya people! Welcome back to another installment of the Texas Tax Roundup. Last month was pretty lowkey (aside from the Legislature’s regular session wrapping up, about which more later). Let’s see what happened!...more