The New Jersey Tax Court held yesterday, February 27, 2019, in a precedential published opinion that a royalty payor was not required to add back any portion of the royalties that it paid to a related licensor under the...more
The Tax Court of New Jersey released its state tax addback decision in Daimler Investments US Corporation v. Director, Division of Taxation on January 31, 2019. The Tax Court agreed with our assertion that amounts Daimler...more
MOFO SALT 2018 YEAR IN REVIEW: CONTINUED SUCCESS IN A CHANGING STATE TAX WORLD -
Following the enactment of the Federal Tax Cuts and Jobs Act in late 2017, many interesting state tax issues emerged concerning states’...more
In Sales and Use Tax Bulletin 2019-01, the Pennsylvania Department of Revenue asserts that remote sellers with economic nexus must collect and remit Pennsylvania sales tax. The Bulletin is effective July 1, 2019....more
The Massachusetts Department of Revenue (“Department”) recently promulgated a proposed amended regulation governing the classification of corporations as “manufacturing corporations” for corporate excise tax purposes (the...more
On June 28, 2018, the Pennsylvania Legislature enacted legislation allowing companies to depreciate bonus depreciation property placed in service after September 27, 2017 pursuant to the normal federal depreciation rules...more
On March 30, 2018, the New York State Legislature approved a compromise 2018–2019 Budget Bill. Among the more significant tax provisions adopted (in bill S. 7509-C/A. 9509-C) were the following...more
The Virginia Supreme Court granted the Company’s petition for rehearing and confirmed that the Department of Revenue’s interpretations that are not contained in regulations are entitled to no weight. ...more
In a 4-3 decision, the Virginia Supreme Court held that the subject-to-tax safe harbor to the royalty addback was ambiguous and applies only to the extent that the royalties are actually taxed by another state. In addition,...more
When must state apportionment be fair? Always. If a state’s normal apportionment formula is operating unfairly with respect to your company, you need to consider the alternatives. The United States Supreme Court has...more
In This Issue:
Ringing in the New Year: Issues from 2013 That Will Likely Impact 2014; Upcoming Speaking Engagements; Defending Against Penalties; and Dueling “Doing Business” Interstate-Commerce Exemptions:...more
In This Issue:
“Occasional Sales” and Single Sales Factor Apportionment in California; Upcoming Speaking Engagements; State Taxation of Financial Institutions; Applying the True Object Test to Determine the Taxability...more
In response to numerous inquiries for copies of our Transcript of ruling and argument following our August 22, 2013 alert, of the New Jersey Tax Court’s bench ruling that the Division of Taxation may not apply dual nexus...more