As a result of the COVID-19 pandemic, many states and localities tried to continue taxing nonresident employees who stopped working from their employer’s location and began working from home in another jurisdiction. The...more
Since the South Carolina Supreme Court held in Media General Communications, Inc. v. South Carolina Department of Revenue, 694 S.E.2d 525 (S.C. 2010), that the Department of Revenue (“Department”) had the authority to allow...more
Blank Rome’s nationally prominent State + Local Tax attorneys are thought leaders in the community as frequent guest speakers at various local and national conferences throughout the year. Our State + Local Tax attorneys...more
While not many states have a uniformity clause in their constitutions, for those that do it can be a powerful tool in a person’s arsenal in challenging a tax. This was recently demonstrated in National Hockey League Players’...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
Although the parties only argued the constitutionality of taxing the gain recognized by a nondomiciliary S Corporation from its sale of a 50 percent interest in a limited liability company (“LLC”), the Massachusetts Supreme...more
The Oklahoma Supreme Court held that a corporation’s refund claim was timely because it was filed within three years from the filing of its original return on extension. In doing so, the Court rejected the Oklahoma Tax...more
The Delaware Supreme Court has invalidated an audit policy that had been in place for at least 30 years as being inconsistent with the Delaware Code, demonstrating that just because a taxing agency’s policy is longstanding,...more
Blank Rome’s nationally prominent State + Local Tax attorneys are thought leaders in the community as frequent guest speakers at various local and national conferences throughout the year. Our State + Local Tax attorneys...more
Blank Rome’s nationally prominent State + Local Tax attorneys are thought leaders in the community as frequent guest speakers at various local and national conferences throughout the year. Our State + Local Tax attorneys...more
The New York State Department of Taxation and Finance has issued guidance on the recently enacted New York Pass-Through Entity Tax. Technical Memorandum, “Pass-Through Entity Tax,” TSB-M-21(1)C, (1)I (N.Y.S. Dep’t of Taxation...more
On April 19, 2021, New York Governor Andrew Cuomo signed into law legislation that creates a New York Pass-Through Entity Tax, effective for tax years beginning on or after January 1, 2021. This consequential tax legislation,...more
While state taxing agencies generally take the high road, it is important to remember that when they do not, the courts can require them to do so. In Wisconsin Department of Revenue v. Deere and Company, No. 2020AP726, 2021...more
On January 19, 2021, New York State Governor Andrew M. Cuomo submitted his Executive Budget, applicable to the state’s fiscal year beginning April 1, 2021. The governor’s proposal, which will now be the subject of public...more