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Worker Classification Litigation on the Rise — An Analysis of the Ninth Circuit’s FedEx Case and Its Lessons for Tax Practitioners

Abraham Lincoln reportedly asked, ‘‘If you call a dog’s tail a leg, how many legs does a dog have?’’ His answer was, ‘‘Four. Calling a dog’s tail a leg does not make it a leg.’’ Similarly, when businesses classify workers,...more

Year-End Tax Planning and Scholarship Tax Credits

The Alabama Accountability Act of 2013 provides state income tax credits to certain donors who make contributions to a qualified scholarship granting organization operating within Alabama, including our client, the Alabama...more

The New Alabama Tax Tribunal Is Open for Business

In March 2014, the Alabama Legislature passed the landmark Alabama Taxpayer Fairness Act (Act No. 2014-146), a substitute to the Alabama Taxpayers’ Bill of Rights II legislation, which had been introduced in various forms...more

10/2/2014  /  New Legislation , Tax Tribunal

New Study by UAB Professor Analyzes Collateral Damage from Internet Sales Tax Non-Compliance

In 2012, Dr. Robert A. Robicheaux, well-respected Professor in the Department of Marketing, Industrial Distribution and Economics at the University of Alabama at Birmingham’s Collat School of Business, issued a report titled...more

Photographers Owe Sales Tax on All Charges Other than Retainer

On September 8, the Alabama Department of Revenue’s Administrative Law Division (the “ALD”) issued a ruling that will likely send shock waves to photographers across the state, and if not successfully appealed or if applied...more

9/19/2014  /  Photographs , Sales & Use Tax

Possible Impact on Alabama Taxpayers: Michigan Supreme Court Rules that IBM Entitled to Use Multistate Tax Compact Election

In International Business Machines Corp. v. Department of Treasury, the Michigan Supreme Court ruled that IBM was entitled to apportion its business income for purposes of the Michigan Business Tax (“MBT”) using the...more

Alabama Tax Tribunal to Issue Proposed Regulations on July 31

Last spring, the Alabama Legislature passed the landmark Alabama Taxpayer Fairness Act, Act # 2014-146, the modified successor to a bill long known as the Alabama Taxpayers’ Bill of Rights II (“TBOR II”). Although the lengthy...more

Judge Bill Thompson Appointed as First Chief Judge of Alabama Tax Tribunal

On May 19, Governor Robert Bentley officially appointed Chief Administrative Law Judge William L. (Bill) Thompson as the first Chief Judge of the newly established Alabama Tax Tribunal (“ATT”) pursuant to the Alabama Taxpayer...more

Mississippi Legislature Overwhelmingly Approves Equifax Fix

Earlier this week the Mississippi Legislature approved the conference committee report on tax reform legislation (House Bill 799) that significantly changes Mississippi’s tax assessment and appeals procedures. Both the House...more

Alabama Legislative Update—Rounding the Corner in the Last Lap: An Update on Pending and Recently Enacted Tax Legislation

The 2014 regular session of the Alabama legislature has been underway for over two months and is nearing its end. The legislature is off this week for Spring Break, then returns on Tuesday, April 1, for three final meeting...more

Alabama Senate Unanimously Approves Bill to Establish an Independent Tax Tribunal

Last night, the Alabama Senate passed by a vote of 26-0 Substitute House Bill 105, formerly known as the Alabama Taxpayers’ Bill of Rights II (TBOR II) and recently renamed the “Alabama Taxpayer Fairness Act,” which...more

Important New and Amended ADOR Regulations Now in Effect

Replacement Local Nexus Rule: The Alabama Department of Revenue’s (ADOR) new local nexus regulation, Rule 810-6-5-.04.02, is now in effect and applies to all transactions occurring on or after January 1, 2014. The ADOR...more

State & Local Tax Alert: Alabama Edition - December 20th, 2013

On December 16, 2013, the Council On State Taxation (COST) released its fifth edition of the COST Due Process Scorecard on Tax Appeals and Procedural Requirements. For the second time in as many scorecards, Alabama ranked in...more

Alabama Tax Developments: 2013 Year in Review

Our final Alabama SALT Alert of 2013 summarizes the major legislative, judicial, and administrative developments affecting Alabama taxpayers with respect to income, transactional, and property taxes so far this year. The 2013...more

12/4/2013

State & Local Tax Alert: Alabama Edition - November 1st, 2013

The Alabama Department of Revenue has just finalized its new local nexus regulation, Ala. Admin. Code Rule 810-6-5-.04.02, that will apply to transactions occurring on or after January 1, 2014, following its rule-making...more

PARCA Issues 25th Anniversary Report: How Alabama’s Taxes Compare

The well-respected Public Affairs Research Council of Alabama (PARCA), headquartered at Samford University in Birmingham, has issued its 25th anniversary report, How Alabama’s Taxes Compare, which discusses the sources and...more

10/9/2013  /  Income Taxes , Tax Reform

State & Local Tax Alert: Alabama Edition - September 25th, 2013

The Alabama Historical Commission has issued emergency regulations to implement the state’s new historic structures rehabilitation tax credit. Emergency Rules 460-x-23-.01ER through 460-x-23-.13ER took effect September 1,...more

Long-standing Regulation Exempting Private Schools from Sales and Use Tax Held Invalid

In a ruling that could have widespread impact, the Alabama Department of Revenue’s (“ADOR”) Chief Administrative Law Judge Bill Thompson held that private schools in Alabama are not exempt from state or local sales and use...more

8/21/2013  /  Private Schools , Sales & Use Tax

Alabama Policy Institute Voices Support for Independent Tax Tribunal in Alabama

For the past several legislative sessions, the Alabama Legislature has considered a bill to establish an independent tax tribunal outside the Alabama Department of Revenue (“ADOR”). Rep. Paul DeMarco (R-Homewood) introduced...more

Alabama Department of Revenue Withdraws and Replaces Proposed Local Nexus Rule - New Proposal Likely to be More Palatable to the...

The Alabama Department of Revenue (“ADOR”) has withdrawn its controversial proposed local nexus rule, Ala. Admin. Code prop. r. 810-6-5-.04.02, and replaced it with a proposal that is narrower in scope and more...more

Eleventh Circuit Rules Alabama’s Sales Tax on Railroads Violates 4R Act; What’s Next?

In the latest decision in the ongoing saga between CSX and the Alabama Department of Revenue (“ADOR”), the Eleventh Circuit U.S. Court of Appeals ruled that Alabama’s imposition of sales tax on diesel fuel purchases by...more

Alabama Department of Revenue to Issue Revised Local Nexus Rule

The Alabama Department of Revenue (“ADOR”) is expected to issue a revised and much less controversial version of its proposed local nexus rule by July 25. The revised rule is expected to be narrower in scope than the...more

Department of Revenue Issues Guidance on the Alabama Accountability Act of 2013

On June 21, the Alabama Department of Revenue (“ADOR” or “Department”) released proposed rules interpreting the landmark Alabama Accountability Act of 2013 (“AAA” or “Act”), Acts of Alabama 2013-64, as amended by Acts of...more

Circuit Court Rules that State-Local Disconformity Cannot Benefit a Local Government

As with many states, Alabama provides an exemption from its sales and use tax if tangible personal property is purchased for the purpose of leasing or renting it to a third party. Alabama Code sections 40-23-1 and 40-23-63(4)...more

Circuit Court Upholds Taxpayer’s WOLF Refund Calculation; Invalidates Retroactive ADOR Regulation

An Alabama circuit court recently held that a taxpayer’s method of calculating a refund under Alabama’s wholesale oil license tax was reasonable, affirming Chief Administrative Law Judge Bill Thompson’s extensive 2009 ruling....more

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