Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more
On October 11, 2022, the Florida District Court of Appeals, First District held oral arguments on State Farm Mutual Automobile Insurance Company v. Florida Department of Revenue, a case relating to the “add back” to...more
In a significant reversal of prior policy, on June 20, 2019, the New York State Assembly and New York State Senate passed Senate Bill 6615, which will exclude 95% of a corporate franchise taxpayer’s gross global intangible...more
The New York State Department of Taxation and Finance released guidance in the form of tax return instructions addressing how it will account for global intangible low-taxed income (referred to as GILTI) for apportionment...more
On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible low-taxed income (GILTI) and...more
12/26/2018
/ Apportionment ,
Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Estate Tax ,
Foreign Derived Intangible Income (FDII) ,
GDP ,
GILTI tax ,
Governor Murphy ,
Internal Revenue Code (IRC) ,
State and Local Government ,
State Tax Equalization Boards ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Revenues
In a year that has seen sweeping changes to the state tax landscape brought about by the Tax Cuts and Jobs Act’s (TCJA) revisions to the Internal Revenue Code (I.R.C. or Code), the majority of state tax focus—with good...more
The year 2018 has been a monumental one for the state and local tax community. If the sweeping changes to the US federal tax code made by the federal Tax Cuts and Jobs Act of 2017 (TCJA) and continued efforts by the states to...more
11/2/2018
/ Capital Gains ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
U.S. Treasury
On June 25, 2018, the New Jersey Legislature passed Assembly Bill 4262 (the Bill) to make several changes to the New Jersey corporation business tax (CBT). Governor Phil Murphy has indicated that he may veto the entire Bill...more
On May 23, 2018, the IRS and the Treasury Department issued Notice 2018-54 announcing their intention to propose regulations addressing the federal tax treatment of state workarounds to the $10,000 ($5,000 in the case of...more
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching...more
4/26/2016
/ Add-Back Legislation ,
Consolidated Tax Returns ,
Debt ,
Foreign Affiliates ,
Franchise Taxes ,
Income Taxes ,
Intercompany Transactions ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Related Parties ,
State Taxes ,
Tax Deductions ,
U.S. Treasury