The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more
It has been widely reported that the Minnesota Legislature has advanced an omnibus tax bill that would require the inclusion of the “entire worldwide income” of combined corporate income tax filers engaging in a unitary...more
For the first time since the enactment of the False Claims Amendment Act of 2020, the DC Attorney General’s (AG’s) Office has used its new tax enforcement powers to pursue an alleged personal income tax deficiency. This...more
The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more
On January 8, SB 2 was introduced to establish a new digital advertising gross revenue tax of up to 10% on “annual gross revenues of a person derived from digital advertising services in the state.” This uncharted new tax...more
1/13/2020
/ Advertising ,
Commerce Clause ,
Constitutional Challenges ,
Digital Communications ,
Equal Protection ,
First Amendment ,
Income Taxes ,
Online Platforms ,
Proposed Legislation ,
State and Local Government ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Rates ,
Tax Returns ,
Tax Revenues
As the economy shifts to a digital one, we are finding that states are turning toward unconventional revenue options. One trend we’re seeing is the surprising comeback of the gross receipts tax (GRT):
• Oregon’s new...more
9/25/2019
/ B&O Tax ,
Business Taxes ,
Commercial Activity Tax ,
Gross Receipts Tax ,
Income Taxes ,
Legislative Agendas ,
Local Ordinance ,
New Legislation ,
Payroll Taxes ,
Proposed Legislation ,
State and Local Government ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Revenues
California legislators have recently introduced a bill, AB 1270, that would amend the False Claims Act (Act) to strike the tax bar. As introduced, the bill would amend the existing false claims statute in the state of...more
Minnesota has several bills pending that would address the Minnesota state tax implications of various provisions of the federal tax reform legislation (commonly referred to as the Tax Cuts and Jobs Act)....more
On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more
3/26/2018
/ Department of Revenue ,
Federal Taxes ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Repatriation ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Liability ,
Tax Reform ,
Trump Administration
It’s been nearly three months since the federal tax reform bill (commonly referred to as the Tax Cuts and Jobs Act, or “TCJA”) was enacted and states continue to respond to the various provisions of the TCJA. Recently, there...more
Virginia and Georgia are two of the latest states to pass laws responding to the federal tax reform passed in December 2017, known as the Tax Cuts and Jobs Act (TCJA). Both states updated their codes to conform to the current...more
States are moving to advance different solutions in their efforts to address federal tax reform. Illinois recently introduced legislation to addback the new deduction for foreign-derived intangible income (a topic we’ve...more
New York is the latest state to address certain state tax implications of the 2017 federal tax reform bill, the Tax Cuts and Jobs Act. Governor Andrew Cuomo’s 30-day amendments to the Governor’s Budget Bill were released on...more
Earlier this month, Connecticut Governor Dan Malloy released his Governor’s Bill addressing the various state tax implications of the federal tax reform bill enacted by Congress in December 2017, commonly referred to as the...more
2/16/2018
/ Dividends ,
Federal Taxes ,
Foreign Earned Income ,
Governor Malloy ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Repatriation ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Trump Administration
While there are differences between the House and Senate tax reform bills that remain to be worked out between the two chambers, both bills are positioned to broaden the tax base and reduce the tax rate. This article...more
After being in effect for only a week, the Council of the District of Columbia (Council) unanimously enacted legislation on November 3, 2015 that will repeal the list of tax haven jurisdictions specifically enumerated in the...more
With many state legislatures wrapping up session within the past month or so, there has been a flurry of last-minute tax amnesty legislation passed. Nearly a half-dozen states have authorized upcoming tax amnesty periods....more
On April 30, 2015, out-of-state professional football players earned victories against the City of Cleveland, Ohio. In a pair of cases decided by the Ohio Supreme Court, the court first struck the City’s method of allocating...more
The Fiscal Year 2016 Budget Support Act of 2015 (BSA), introduced by the Washington, D.C. Council at the request of Mayor Muriel Bowser on April 2, 2015, contains a subtitle (see Title VII, Subtitle G, page 66-67) that would...more
Starting September 1, 2015, the Comptroller of Maryland (Comptroller) will offer qualifying taxpayers that failed to file or pay certain taxes an opportunity to remit tax under very attractive penalty and interest terms. The...more
On September 23, District of Columbia Council Chairman Mendelson introduced the Promoting Economic Growth and Job Creation Through Technology Act of 2014 (Bill 20-0945 , hereinafter the “Act”) at the request of Mayor Vincent...more
It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more
On July 14, 2014, the Fiscal Year 2015 Budget Support Emergency Act of 2014 (2015 BSEA) was enacted after the D.C. Council voted to override Mayor Vincent Gray’s veto. The act includes a tax relief package recommended by the...more
In Wirth v. Commonwealth, the Supreme Court of Pennsylvania held that Pennsylvania personal income tax applied to non-resident limited partners whose only connection with the state was the ownership of a small interest in a...more
In This Issue:
- Waiver of Privilege: Disturbing Trends
- New Repair Regulations Affect All Taxpayers
- Unclaimed Property – It Is Not a Tax, but It Can Feel Like One
- Excerpt from Waiver of...more