On July 30, the New Jersey Division of Taxation (the “Division”) issued a new technical bulletin (TB-79) concerning corporate income tax nexus and the scope of federal immunity under 15 U.S.C.A section 381 (“P.L. 86-272”)....more
Fund Managers May Be Taxable in California, Even if the Manager Has No Property or Payroll in California and All of the Management Services Are Performed Outside of the State.
Several recent law changes in California,...more
Four years after enacting the largest tax increase in Connecticut history, the Connecticut General Assembly has adopted a new $40.3 billion biennial state budget that contains $1.5 billion in tax and fee increases.
The San Francisco Office of the Treasurer and Tax Collector recently issued Gross Receipts Tax regulations, tax return filing instructions and other guidance addressing major changes to how owners of disregarded entities are...more
For years, both the New York State Department of Taxation and Finance (the “Department”) and the New York City Department of Finance have aggressively sought to classify receipts generated by electronic or online service...more
The law is an ass, or so says Charles Dickens. After reading the IRS’ latest missive on sales of marijuana, I think I agree.
The tension between federal and state law on the sale of marijuana carries over to federal income...more
San Francisco’s gross receipts tax (GRT) began phasing in this year and will be fully implemented in 2018. While the tax rates are lower than those under the previous payroll tax system, the GRT may lead to higher taxes for...more
With the November 4th election of Democrat Tom Wolf as Pennsylvania’s next Governor, Pennsylvania corporate taxpayers face an interesting budget season in 2015. During the campaign, Wolf advocated for a severance or...more
This is a brief update on recent Pennsylvania tax developments.
Does New Governor Mean More Tax Reform?
In the recent gubernatorial election, challenger Tom Wolf (D) defeated incumbent Governor Tom Corbett (R)....more
A divided panel of the Commonwealth Court held that a city was not prohibited from imposing its Business Privilege Tax on the gross receipts of a freight broker. S & H Transport, Inc. v. City of York, No. 165 C. D. 2014 (Pa....more
In a Corporation Business Tax (CBT) case, PPL Electric Utilities Corporation v. Director, Division of Taxation, Dkt. No. 000005-2011 (N.J. Tax. Ct. Oct. 2, 2014), the Tax Court of New Jersey found for the taxpayer and held...more
On October 2, in PPL Electric Utilities Corporation v. Director, Division of Taxation, No. 000005-2011, the New Jersey Tax Court determined that federal deductions for the taxpayer’s payments of Pennsylvania gross receipts...more
More than 40 Washington cities impose local business and occupation (B&O) tax. This is in addition to the state’s B&O tax on gross receipts. When a business engages in activities both inside and outside a B&O tax city,...more
The first installment payment for the new San Francisco Gross Receipts Tax was due April 30, 2014. Many questions about the new tax remain. While the City has provided some relief from installment underpayment penalties,...more
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
James Susa analyzes the state tax statutory structures and major court decisions on bad debt deductions and concludes that in practice, the availability of such a deduction is limited in scope.
Each state that imposes...more
In This Issue:
PA Capital Stock/Franchise Tax Phase-Out Deferred; PA Board of Finance and Revenue Reconstituted as Independent Tax Tribunal; Annual PA Property Valuation Appeals Due Soon; Telecom Gross Receipts Tax...more
The recently concluded 2013 regular session of the New Mexico Legislature resulted in legislation enacting several significant changes to New Mexico’s tax programs, the majority of which are business friendly. Most of the...more
This is a brief update on recent Pennsylvania tax developments. It is intended to provide an overview of issues and cases to watch, as well as administrative and legislative developments....more
The Tennessee Department of Revenue has released a legislative proposal with the stated intent of clarifying the application of the locally-imposed business tax to out-of-state businesses while also codifying an existing...more
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