On February 5, 2024, the Offices of the Controller and Treasurer & Tax Collector for the City and County of San Francisco published a report outlining tax reform recommendations in time to inform a potential ballot measure...more
Things have been heating up this summer. Let’s see what’s been cooking with the Texas Comptroller’s office....more
It’s a letter that no one looks forward to—a notice of determination (also sometimes called a “Notification of Audit Results,” “Notification of Exam Results,” or “Notice of Tax/Fee Due”) from the Texas Comptroller of Public...more
Oregon State Senator Fred Girod, a Republican from Stayton, Oregon (District 9), is sponsoring Senate Bill 787 ("SB 787"). If passed, SB 787 would repeal the Oregon Corporate Activity Tax (the "CAT"). So far, the bill does...more
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
On May 4, 2020, the Oregon Department of Revenue (“DOR”) issued a new draft rule regarding the Oregon Corporate Activity Tax (“CAT”). This draft rule provides guidance to assist taxpayers in determining the sourcing of...more
A common question in many Ohio commercial activity tax (CAT) audits is whether federal tax treatment may be relied upon. Although the statute says it should (R.C. 5751.01(K)), the Tax Commissioner is often reluctant to accept...more
On January 21, A. 9112 was introduced in the New York Assembly. An identical Senate companion bill, S. 6102, has been referred to the Senate Budget & Revenues Committee after being introduced in May 2019. The bills would...more
Retailers and brand owners should be mindful of recent UK tax developments that impact taxation of gross receipts and taxation of digital activities. The new income tax charge on offshore receipts from intangible property...more
The Ohio Board of Tax Appeals recently allowed a taxpayer to retroactively elect to be taxed as a consolidated taxpayer for Ohio commercial activity tax, even after an audit had commenced. Nissan North America, Inc. v....more
We have recently discussed in several blog posts Oregon’s new Corporate Activity Tax (“CAT”), a gross receipts tax that will become effective January 1, 2020. As we announced in our most recent post on this topic, the Oregon...more
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”) regarding the base erosion and anti-abuse tax (generally referred to as the...more
For more than a year, I have been discussing the potential that Oregon lawmakers will pass a corporate gross receipts tax. On May 26, 2017, we discussed recent events that would lead a reasonable person to believe that the...more
Nevada likes to market itself as a low tax jurisdiction, touting the fact that “Nevada does not impose income tax on domestic or foreign corporations.” It may not impose a tax on income, but it does impose a tax on...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
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
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