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Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 2, 2024

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

Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 1, 2024

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

Blank Rome LLP

New York City Announces Anticipated Deviations from Recently Promulgated New York State Corporate Tax Regulations

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The New York City Department of Finance (“Department”) has recently announced on its website that its still-pending business corporation tax regulations under City corporate tax reform legislation enacted in 2015 are expected...more

Kilpatrick

Laying Out the Basics of the Illinois Franchise Tax

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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

Kilpatrick

Calculating Allocation Factor for Illinois Franchise Tax Purposes

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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

Kilpatrick

Commons Problems and Simple Solutions

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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

Eversheds Sutherland (US) LLP

Georgia’s 2024 legislative session: Sine Die tax legislation overview

The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more

Williams Mullen

2023 Developments in Virginia Taxation

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A Summary Review of Tax Legislation, Court Decisions, Opinions of the Attorney General and Published Rulings of the Tax Commissioner Published from January 1, 2023 through November 10, 2023....more

Eversheds Sutherland (US) LLP

New York adopts final business corporation franchise tax regulations

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

Blank Rome LLP

Michigan Tax Tribunal Holds That Parent Properly Excluded its Wholly Owned Subsidiary from its Unitary Business Group Return

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Challenging a state corporate tax determination of a unitary business relationship between related corporations can be difficult. However, a recent decision of the Michigan Tax Tribunal shows that with good facts a business...more

Nutter McClennen & Fish LLP

Estate and Income Tax Provisions in Pending Massachusetts Tax Relief Package

The Massachusetts House and Senate voted in favor of a Massachusetts tax relief bill. The legislation is now on Governor Maura Healey’s desk, and she has until October 8th to act. More than two decades have passed since the...more

Blank Rome LLP

New Jersey Still Wrestles with Unity, but Don’t Forget the Rules

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As the New Jersey Division of Taxation changes leadership and issues guidance regarding legislative changes, including for unity, it is time to recall some fundamentals of unity and put the unity statute change in context....more

Blank Rome LLP

New Jersey Makes Substantial Changes to the Corporation Business Tax

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On July 3, 2023, New Jersey Governor Phil Murphy signed into law S.B. 3737 / A.B. 5323 (the “Bill”), which makes significant changes to the Corporation Business Tax (“CBT”). Some of the most noteworthy changes are summarized...more

Williams Mullen

Virginia Dept of Tax Issues Clarifying Guidance for Recent Changes to Pass-Through Entity Tax

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The General Assembly enacted legislation (H.B. 1456 and S.B. 1476) during its 2023 Regular Session that removed some of the barriers for qualifying for Virginia’s Pass-Through Entity Tax (PTET) election and altered how PTET...more

Stoel Rives LLP

Washington Supreme Court Upholds Capital Gains Tax

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Effective January 1, 2022, Washington law imposes a 7% tax on gains over $250,000 per year from the sale or exchange of long-term capital assets allocated to Washington such as stocks, bonds, business interests, or other...more

Blank Rome LLP

Whose Income Producing Activity Is It Anyway?

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Both states and taxpayers have struggled with how to correctly source service receipts for apportionment purposes. The myriad of state sourcing provisions certainly do not add any clarity to the issue. Muddying the waters...more

Blank Rome LLP

Massachusetts Commissioner of Revenue Issues Guidance Seeking to Limit Taxpayer Win in Apportionment Case

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In the wake of the taxpayer win at the Supreme Judicial Court of Massachusetts in VAS Holdings & Investments LLC v. Commissioner of Revenue, 489 Mass. 669 (2022) (“VAS”), the Commissioner of Revenue has issued guidance in the...more

Nossaman LLP

Federal and California Tax Agencies Announce Relief Measures for Storm-Impacted Taxpayers

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Federal and California tax agencies have announced several relief measures for taxpayers affected by the storms that started shortly before New Year’s Eve and ended (for the time being) on Martin Luther King Jr. Day. Natural...more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

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The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

Blank Rome LLP

Interest Payment Not Required to Be Added Back as Alabama’s Subject-To-Tax Exception Applied

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On July 28, 2022, the Alabama Tax Tribunal held that a corporation is not required to add back interest paid to a related entity as the recipient was subject to tax on that income in Ireland. This was so even though the...more

Cozen O'Connor

Pennsylvania Enacts Record Tax Reform

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Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, P.L. __. No. 53 (Act 2022-53) (HB 1342) implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions. The bill will:.....more

McNees Wallace & Nurick LLC

Pennsylvania – “Open for Business” or “Open to Tax”

Governor Wolf and other Pennsylvania lawmakers recently passed the state budget for FY22-23 (the “Budget”). Coming in at $45.2 billion, the negotiations entailed to finalize the Budget appear to be worth the effort by having...more

Ballard Spahr LLP

Pennsylvania Cuts Corporate Income Tax Rates, Makes Other Significant Tax Changes

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Pennsylvania’s budget season just ended and Act 53 of 2022 (Act 53), made many significant changes to the Commonwealth’s business and individual taxes....more

Sands Anderson PC

Virginia’s New Elective PTE Tax and SALT Cap Workaround

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Elective PTE Income Taxes Payable to Virginia - Beginning July 1, 2022, Virginia’s new law establishing a workaround for the federal income tax limitation on deductions for state and local taxes (SALT) became effective....more

Smith Anderson

North Carolina Tax Legislation Enacted in the 2022 Short Session

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The North Carolina General Assembly ended its 2022 short session on July 1. While the legislature is scheduled to reconvene on July 26, no additional tax legislation is expected to be considered....more

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