The Michigan Court of Appeals recently reaffirmed its earlier decision that an alternative method of apportionment was necessary to avoid unconstitutional distortion from including a large gain from the sale of a...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 July 15, 2021, the Ohio Supreme Court reversed the Board of Tax Appeals (“BTA”) and held that two taxpayers had timely filed appeals from final determinations of the Tax Commissioner (“Commissioner”) as a result of tolling...more
The Massachusetts Supreme Judicial Court denied the Commissioner of Revenue’s attempted money grab and held that there is a statutory right to apportion sales tax on receipts from the sale or license of software that was...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
Income & Franchise Taxes—Deductions -
Massachusetts—Appeals Court Allows Deduction for Utility Taxes Paid to Indiana -
The Massachusetts Appeals Court reversed a decision of the Appellate Tax Board and allowed Bay State...more