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Potential State and Local Tax Implications of the U.S. Supreme Court’s Decision in Loper Bright Enterprises v. Raimondo

On June 28, 2024, the U.S. Supreme Court issued its decision in Loper Bright Enterprises et. al. v. Raimondo, Secretary of Commerce, et. al., No. 22-451 603 U.S. ___, (June 28, 2024), in which it held that in interpreting...more

New Jersey Tax Court Awards Company a Refund Based on Its Use of Market-Based Sourcing for Years Prior to New Jersey’s Adoption of...

In an unpublished opinion, the New Jersey Tax Court held that a web-based business solutions company was entitled to use market-based sourcing to source its 2011 and 2012 receipts even though market-based sourcing was not...more

New York ALJ Rejects Division of Taxation’s Attempt to Change Its Theory of Liability after the Hearing

A New York State Administrative Law Judge (“ALJ”) recently rejected an attempt by the Division of Taxation (“Division”) to change its theory of liability after the record was closed, raising its new theory of liability for...more

New York State Tax Appeals Tribunal Denies Resident Credit for Tax Paid to Connecticut on Carried Interest

The New York State Tax Appeals Tribunal ("Tribunal") held that a New York resident was not entitled to a resident tax credit for tax she paid to Connecticut on her carried interest. Matter of Greenberg, DTA No. 829737 (N.Y.S....more

California Governor Signs a Handful of Tax-Related Bills into Law

This fall, California Governor Gavin Newsom signed several tax-related bills into law on a diverse array of topics ranging from the use tax to the gun tax. Use tax: On October 7, 2023, Governor Newsom signed a bill into...more

New York State Formally Proposes Regulations Implementing 2014 Corporate Tax Reform

On August 9, 2023, the New York State Department of Taxation and Finance (the “Department”) formally proposed Business Corporation Franchise Tax Regulations under the State Administrative Procedure Act (“SAPA”). The proposed...more

New Jersey Makes Substantial Changes to the Corporation Business Tax

On July 3, 2023, New Jersey Governor Phil Murphy signed into law S.B. 3737 / A.B. 5323 (the “Bill”), which makes significant changes to the Corporation Business Tax (“CBT”). Some of the most noteworthy changes are summarized...more

New Jersey Division of Taxation Issues Guidance on S Corporation Procedures

On December 22, 2022, New Jersey enacted P.L. 2022, c. 133, which changed the Corporation Business Tax and Gross Income Tax procedures for S corporations. Most significantly, for privilege periods beginning on or after...more

New York State ALJ Determines Vendor Management Services Provided in Conjunction with Software are Subject to Sales Tax as the...

An Administrative Law Judge (“ALJ”) recently found that a taxpayer’s vendor and labor management services, which were provided in conjunction with the grant of a software license, were subject to sales tax as the sale of...more

New York State ALJ Determines Individual Member of LLC Personally Liable for Sales Tax

An Administrative Law Judge (“ALJ”) recently determined that an individual member of a limited liability company (“LLC”) was personally liable for an LLC’s sales tax deficiency, both because he was a member of the LLC, and...more

ALJ Determines E-Mail Tracking and Analytics Services Not Subject to New York Sales Tax

An Administrative Law Judge (“ALJ”) recently issued a determination cancelling the notices of determination issues by the New York State Department of Taxation and Finance and finding that the taxpayer’s e-mail tracking and...more

Appellate Division Holds That Existence of Vacation Home Not Enough to Establish Statutory Residency in New York

The Appellate Division recently granted taxpayers an important victory when it overturned the decision of the Tax Appeals Tribunal and held that a New Jersey resident’s vacation home in upstate New York was not enough to...more

New York State Updates Draft Corporate Franchise Tax Regulations

On April 29, 2022, the New York State Department of Taxation and Finance (the “Department”) released what it refers to as a “final update” to its draft corporate franchise tax regulations relating to all topics except for...more

New York State Updates Nonresident Audit Guidelines

The New York State Department of Taxation and Finance recently revised its Nonresident Audit Guidelines for the first time in seven years. This updated version, issued in December 2021, replaces the guidelines that were...more

State Barred by Statute of Limitations from Recovering an Erroneous Refund Payment

The New Jersey Tax Court recently granted a pro se taxpayer’s motion for summary judgment and ruled that the Division of Taxation was barred by the statute of limitations from recovering an erroneous income tax refund payment...more

California Franchise Tax Board Issues Legal Ruling on Unity of Holding Companies

On October 25, 2021, the California Franchise Tax Board (“FTB”) issued a legal ruling providing guidance on the issue of when pass-through entity holding companies will be considered unitary with the pass-through entities in...more

New York State ALJ Determines Taxpayer Was Domiciled in New York for Part of the Year and a Statutory Resident for the Other Part

A New York State administrative law judge (“ALJ”) recently determined that a teacher who became domiciled in New York in December 2014 upon his purchase of an apartment in New York City was also a statutory resident of New...more

Connecticut Enacts Budget Bill Extending Business Tax Surcharge, Delaying Capital Base Tax Phaseout, and Creating a Tax Amnesty...

On June 23, 2021, Connecticut Governor Ned Lamont signed into law two budget bills comprising the state budget for the fiscal year 2022-2023 (the “Budget Bill”). H.B. 6689, S.B. 1202. The Budget Bill contained several...more

New York Enacts Changes to Liability Provisions of New York Real Estate Transfer Tax

On April 7, 2021, the New York State Legislature passed the New York Budget Bill for fiscal year 2022 which was signed by Governor Andrew Cuomo on April 19, 2021 (the “Budget Bill”). S.B. S2509C, 2021 Leg., 2021 Reg. Sess....more

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