The Minnesota Supreme Court has held that market research conducted by an out-of-state company’s sales representatives when visiting in Minnesota exceeded “solicitation of orders” and therefore, the company was not protected...more
The New York City Department of Finance (“Department”) has recently announced on its website that its still-pending business corporation tax regulations under City corporate tax reform legislation enacted in 2015 are expected...more
In a pair of decisions, a New York State appellate court has annulled decisions of the New York State Tax Appeals Tribunal that reduced certain tax credits available to the individual shareholders of their S corporation....more
Challenging a state corporate tax determination of a unitary business relationship between related corporations can be difficult. However, a recent decision of the Michigan Tax Tribunal shows that with good facts a business...more
In this article, the author discusses a recent decision by a federal district court in New York that demonstrates the potential benefits of working with the New York State Tax Department to resolve qui tam claims, even where...more
A recent decision involving the New York City unincorporated business tax addback for payments to partners is an important reminder that the addback may sometimes be applied even for payments that are not made to a partner of...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
Now that the COVID-19 pandemic has dissipated, states and localities have begun to end temporary tax policies that were meant to provide relief to some taxpayers from the restrictions imposed by government during the...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
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