The November 30, 2023, opinion of a New York administrative law judge in In the Matter of the Petition of Edward A. and Doris Zelinsky upholds the state’s so-called income tax “convenience rule” with an expanded legal...more
Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises. The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more
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
The General Assembly reconvened for Legislative Day 36 on Monday with lawmakers and lobbyists hoping to keep a little luck of the Irish going into the penultimate week of the legislative session. With only four legislative...more
The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the...more
If you own property in Michigan, then you just received (or will soon receive) a Notice of Assessment, Taxable Valuation and Property Classification from your local city or township. The phrase “THIS IS NOT A TAX BILL” is...more
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
Asset managers established as LLPs will welcome the Upper Tribunal’s recent decision to uphold the decision of the First Tier Tax Tribunal (“FTT”) on the application of the salaried member rules in Bluecrest...more
New York Governor Kathy Hochul and the New York State Legislature have reached an agreement on the state’s fiscal year 2024 budget legislation. Most surprisingly, the legislation grants the New York State Department of...more
A recent Tax Tribunal decision, Mark E. Bollinger v. State of Alabama Department of Revenue, Inc. 22-390-LP, should be of interest to Alabama employers using remote workers. In this case, Mark Bollinger worked for a large...more
In 2021, the Georgia Tax Tribunal ruled that a non-profit hospital was entitled to use Quality Jobs Tax Credits (QJTC) against its unrelated business income tax and its payroll withholding tax. Floyd Healthcare Mgmt., Inc. v....more
The Upper tax tribunal (“Upper Tribunal”) has confirmed the decision of the First-tier tax tribunal (“FTT”), delivered in 2021, in the case of Kwik-Fit Group Limited and others v HMRC. This decision of the Upper Tribunal...more
There seems to be an increased number of so-called “residency audits” being conducted by the Alabama Department of Revenue (ALDOR), as well as by other state tax authorities. These audits often result from the taxpayer filing...more
We summarize here what we believe are the top 5 Alabama tax cases decided in the past year that would interest our CPA readers. Not surprisingly, almost all are Alabama Tax Tribunal rulings, so in those instances we deleted...more
Last week, Governor Murphy of New Jersey staked out a position on New York City’s congestion pricing proposal, stating that it “can’t be ‘on the backs of New Jersey commuters.’” “Whether it’s how we’re taxed by our...more
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
In this blog, we consider the First-tier Tribunal (Tax Chamber)’s recent update to its guidance for parties wishing to rely on evidence given by a witness from outside the UK. The First-tier Tribunal (Tax Chamber) (the...more
Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more
Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more
During the 2022 legislative session, the Georgia General Assembly passed significant tax legislation, including authorizing affiliated groups to file consolidated corporate income tax returns without prior approval from the...more
“Yes” to Art, “No” to Tax- Private patronage of the arts. For centuries, artists, museums, and galleries have depended, in no small part, upon the largesse of wealthy families. Today, as in the past, many of these...more
The New York State sales tax on “protective and detective services” has been given an expansive reading by the New York State Tax Appeals Tribunal in a decision involving information technology (“IT”) security services. In In...more
The New York State Tax Appeals Tribunal held that an information service was not subject to sales tax because although the service provider had the right to provide the information to others, it did not have the technical...more
The Alabama Tax Tribunal held the taxpayers’ wholesale sales of fuel that entered and exited the state via the Colonial Pipeline were subject to the state’s wholesale oil license fee. The sales in question were made to...more
In Matter of Goldman Sachs Petershill Fund Offshore Holdings (Delaware) Corp., the New York City Tax Tribunal held that an upper-tier partnership’s passive corporate partner was subject to the New York City General...more