In March, the Internal Revenue Service published an IRS Large Business & International (LB&I) Directive (the Directive), which updates an earlier directive to field agents addressing the examination of capitalization and...more
Warning! Proceed with care: owners of heritage immovables are now subject to much more stringent rules including with respect to the preservation of the heritage value of their immovables. In the Fall of 2012, a new act was...more
There is a storm on the horizon for providers of cloud-based services as states determine whether and how to tax these services. Service providers should act now to anticipate upcoming tax issues for their particular...more
The release of software may require an export control license from the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) under the Export Administration Regulations (the “EAR”). Software delivery has...more
Originally published in State Tax Notes.
Many states have created special treatment for manufacturers, including tax exemptions, credits, and special income tax apportionment rules. In this edition of A Pinch of SALT, we...more
Code §2501(a)(2) provides that, except as to certain expatriates, U.S. gift taxes do not apply to the transfer of intangible property by a nonresident not a citizen of the United States. This exemption is big enough to drive...more
Recent developments in state tax laws include a non-titled tangible personal property use tax in Cook County, Illinois, that is effective on April 1, 2013; and an income tax increase on individuals, estates and trusts in...more
If you are located in Virginia and use a cloud computing service, and you (or your cloud provider) received a disk, manual, or other incidental tangible property in connection with your purchase of the service, you may have...more
Earlier this week, the California Court of Appeal, First District, held that the right to replicate and install software is an intangible property right for sales-factor sourcing purposes. Thus, for the years at issue, the...more
On December 18, 2012, the California Court of Appeal ruled that receipts from the right to replicate software are sourced as sales “other than tangible personal property.” In reversing the trial court, the Court of Appeal...more
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