A recent Rhode Island Administrative Hearing Decision addressed whether an online database that incorporates searchable research is taxable as vendor-hosted prewritten computer software. [R.I. Div. of Tax’n, Administrative...more
2/10/2026
/ Administrative Appeals ,
Appeals ,
Cloud Computing ,
Digital Goods ,
Regulatory Requirements ,
Rhode Island ,
SaaS ,
Software ,
State and Local Government ,
State Taxes ,
Statutory Interpretation ,
Taxation
Not surprisingly, state Department of Revenues are finally addressing the taxability of Artificial Intelligence (AI) components. The Kentucky Department of Revenue recently issued guidance in its Winter 2025/2026 Sales Tax...more
1/29/2026
/ Artificial Intelligence ,
Cloud Computing ,
Information Technology ,
New Guidance ,
Regulatory Requirements ,
SaaS ,
Sales Tax ,
Software ,
State and Local Government ,
State Taxes ,
Tax Liability ,
Taxation ,
Technology Sector
Over the course of a few weeks, the Ohio Supreme Court has released a pair of decisions that offer guidance on how to determine the situs of gross receipts for purposes of calculating the Commercial Activity Tax (CAT) as well...more
1/23/2026
/ Appeals ,
Appellate Courts ,
Business Taxes ,
Commercial Activity Tax ,
Jurisdiction ,
OH Supreme Court ,
Refunds ,
State and Local Government ,
State Taxes ,
Statutory Interpretation ,
Supply Chain ,
Tax Liability ,
Tax Refunds ,
Taxation
Investment in data centers continues to increase significantly as the country builds out infrastructure to accommodate the digital economy and growth of artificial intelligence. Many states, including Texas, have now...more
1/16/2026
/ Data Centers ,
Electricity ,
Energy Sector ,
Hydrogen Power ,
Infrastructure ,
Investors ,
Natural Gas ,
Private Letter Rulings ,
Sales & Use Tax ,
State Taxes ,
Tax Exemptions ,
Tax Incentives ,
Tax Liability ,
Taxation ,
Texas
In 2018, the Alabama Legislature passed Alabama Act 2018-180, which changed the procedure for consumers petitioning for refunds of Utility Gross Receipts Tax (UGRT), sales or use tax, or transient occupancy tax. Prior to Act...more
12/22/2025
/ Alabama ,
Sales & Use Tax ,
State and Local Government ,
State Taxes ,
Statute of Limitations ,
Statutory Interpretation ,
Tax Appeals ,
Tax Legislation ,
Tax Refunds ,
Tax Tribunal ,
Taxation
New Hampshire passed legislation this year to establish a one-time opportunity for taxpayers to pay all outstanding taxes and receive amnesty from penalties and one-half of the interest that has accrued since the tax was due....more
11/26/2025
/ Department of Revenue ,
Filing Deadlines ,
Interest Payments ,
New Legislation ,
Penalties ,
State and Local Government ,
State Legislatures ,
State Taxes ,
Tax Amnesty ,
Tax Appeals ,
Tax Legislation ,
Tax Liability ,
Tax Penalties ,
Tax Relief ,
Tax Returns
Across the country, states have been moving towards increased judicial oversight and reduced reliance on agency interpretations over the past few years either through court decisions, legislation, and even a ballot measure....more
11/19/2025
/ Appellate Courts ,
Auer Deference ,
Chevron Deference ,
Chevron v NRDC ,
De Novo Standard of Review ,
Department of Revenue ,
Government Agencies ,
Judicial Authority ,
Judicial Review ,
Loper Bright Enterprises v Raimondo ,
NC Supreme Court ,
Regulatory Authority ,
Regulatory Oversight ,
SALT ,
State Agencies ,
State and Local Government ,
State Taxes ,
Statutory Interpretation ,
Tax Litigation ,
Taxation
A recent property tax decision from the Connecticut Appellate Court, McHenry Solar, LLC v. Town of Hampton, Conn. App. Ct., Dkt. No. AC 47636, 09/23/2025, may also have sales tax implications.
In McHenry, the taxpayer sought...more
10/28/2025
/ Appellate Courts ,
Clean Energy ,
Connecticut ,
Energy Projects ,
Property Tax ,
Renewable Energy ,
Sales & Use Tax ,
Sales Tax ,
Solar Energy ,
State and Local Government ,
State Taxes ,
Tax Appeals ,
Tax Exemptions ,
Tax Planning
In BellSouth Telecommunications, LLC et al. v. Ala. DOR, Ala. Tax Tribunal, Dkt. No. S. 22-829-LP (Sep. 23, 2025), the Alabama Tax Tribunal upheld the Department of Revenue’s denial of a sales tax refund sought by a...more
10/2/2025
/ Alabama ,
Department of Revenue ,
Fiber Optic Cables ,
Sales Tax ,
SALT ,
State and Local Government ,
State Taxes ,
Tax Appeals ,
Tax Exemptions ,
Tax Litigation ,
Tax Rates ,
Tax Refunds ,
Tax Tribunal ,
Telecommunications
Like many states, Minnesota uses a market-based approach for calculation of the corporate franchise tax apportionment, by sourcing sales of services to the state where the services are “received.” A recent decision by the...more
10/2/2025
/ Apportionment ,
Corporate Taxes ,
Department of Revenue ,
Franchise Taxes ,
MN Supreme Court ,
Pharmacy Benefit Manager (PBM) ,
SALT ,
State and Local Government ,
State Taxes ,
Statutory Interpretation ,
Tax Appeals ,
Tax Court ,
Tax Litigation ,
Tax Refunds
On July 10, 2025, Missouri Governor Mike Kehoe signed House Bill 594 into law, amending RSMo. § 143.121 to exempt capital gains from its existing state income tax. For tax years beginning on or after January 1, 2025, income...more
7/22/2025
/ Adjusted Gross Income ,
Business Entities ,
Business Ownership ,
Capital Gains ,
Capital Gains Tax ,
Income Taxes ,
Pass-Through Entities ,
State Taxes ,
Tax Benefits ,
Tax Legislation ,
Tax Liability ,
Tax Reform
On July 3, 2025, Wisconsin Governor Tony Evers signed 2025 Wisconsin Act 15 into law, marking a significant milestone for the telecommunications industry in the state. This new legislation specifically exempts radio,...more
7/9/2025
/ Appeals ,
Cell Towers ,
Commercial Property Owners ,
Governor Evers ,
Landlords ,
New Legislation ,
Property Tax ,
State Taxes ,
Tax Exemptions ,
Tax Reform ,
Telecommunications ,
Tenants ,
Wisconsin
In the wake of the COVID-19 pandemic and increased remote work, multistate income tax and payroll tax withholding responsibilities have received heightened consideration nationwide. Employers keen on retaining and attracting...more
7/2/2025
/ Alabama ,
Coronavirus/COVID-19 ,
Corporate Taxes ,
Employees ,
Employer Liability Issues ,
Employer Responsibilities ,
Income Taxes ,
New Legislation ,
Non-Residents ,
Payroll Taxes ,
Remote Working ,
SALT ,
State Taxes ,
Tax Exemptions
As part of a continuing trend, Kansas Governor Laura Kelly has signed SB98 into law, becoming the latest state to enact a sales tax exemption for qualified data centers. Many states, including neighboring Missouri (see RSMo....more
5/27/2025
/ Data Centers ,
Economic Development ,
Incentives ,
Investment ,
Kansas ,
New Legislation ,
Regulatory Requirements ,
Sales Tax ,
State and Local Government ,
State Taxes ,
Tax Exemptions ,
Technology Sector
The Michigan Department of Treasury recently issued updated guidance addressing successor liability in response to Mertz v. Dep’t of Treasury [Dkt. No. 365480 (June 13, 2024)], a recent case before the Michigan Court of...more
Nevada law requires taxpayers to meet certain prerequisites before seeking judicial review of a Nevada Tax Commission decision. Taxpayers must either pay the amount at dispute or enter into a written agreement with the Nevada...more
Public Law 86-272 (P.L. 86-272) was first adopted by the U.S. Congress in 1959 to address the business concerns of tax implications from traveling salesmen working in multiple states. To address these concerns, Congress used...more
3/14/2025
/ Business Taxes ,
Commerce Clause ,
Income Taxes ,
Multistate Tax Commission (MTC) ,
New Jersey ,
Proposed Rules ,
Regulatory Requirements ,
State and Local Government ,
Tax Liability ,
Tax Reform ,
Tax Returns
New Mexico’s gross receipts tax (what the state calls its sales tax) is generally imposed on receipts derived by the seller from performing services in the state; however, a resale of the services is not generally taxable if...more
2/25/2025
/ Compliance ,
Department of Revenue ,
Exemptions ,
Gross Receipts ,
Health Care Providers ,
Healthcare ,
Hospitals ,
Provider Payments ,
Regulatory Requirements ,
State and Local Government ,
State Taxes ,
Tax Credits ,
Tax Liability ,
Taxation
As digital products and services continue to proliferate, states have begun to address the sales tax implications of sales of Software as a Service (SaaS) in a variety of ways. While a few states have clearly addressed how...more
A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more
1/29/2025
/ Compliance ,
Corporate Taxes ,
Dividends ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
New Jersey ,
State and Local Government ,
State Taxes ,
Tax Court ,
Tax Liability ,
Tax Planning ,
Tax Returns
On May 25, 2023, the U.S. Supreme Court held that a Minnesota county’s retention of the excess proceeds from sale of a homeowner’s property to satisfy a tax lien violated the Takings Clause. This decision recognizes that...more
6/2/2023
/ Abandonment ,
Asset Seizure ,
Eminent Domain ,
Fifth Amendment ,
Forfeiture ,
Fourteenth Amendment ,
Property Tax ,
SCOTUS ,
Takings Clause ,
Tax Debt ,
Tax Sales ,
Tyler v Hennepin County Minnesota
On May 4, 2023, Indiana Governor Eric Holcomb signed legislation (Laws 2023, SB419) that, among other tax changes, included provisions to exempt from income tax nonresidents receiving compensation for employment duties...more
In the latest skirmish in an ongoing battle between taxing authorities and institutions of higher education, the Nebraska Tax Equalization and Review Commission recently affirmed a decision that denied a property tax...more
Spring is in the air, and so is property tax assessment and appeal season. Each municipality has different procedures and deadlines on advising its taxpayers of the 2023 tax assessments. These deadlines are critical and, if...more
In November 2022, the Supreme Court of Wisconsin clarified the procedural requirements for taxpayers to challenge their property taxes. Although several taxpayers historically filed protective refund claims upon receipt of...more