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California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more

New Jersey Tax Court Approves Use of Market-Based Sourcing for Years Prior to Legislature’s Adoption of Market-Based Sourcing

The New Jersey Tax Court held that a taxpayer was entitled to a refund of corporation business tax (CBT) for tax years 2011 and 2012 after determining the taxpayer correctly used a market-based sourcing methodology to source...more

South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department

Under a new bill signed into law on March 11, 2024, the South Carolina Department of Revenue will have to satisfy additional standards before it may force affiliated corporate taxpayers to file a unitary combined return. ...more

Certainly COP: Florida Court Rejects Department of Revenue’s Attempt to Conflate Costs of Performance Sourcing With Market-Based...

On March 1, 2023, a Florida trial court confirmed that costs of performance (COP) sourcing, not market-based sourcing, is Florida’s standard methodology for sourcing service receipts for apportionment purposes.  In Billmatrix...more

Massachusetts High Court Approves of Apportionment of Sales Tax on Software Through General Abatement Process

The Massachusetts Supreme Judicial Court recently held that software vendors have a statutory right to apportion tax on the sale of prewritten computer software purchased for use in multiple states and that they may do so...more

Maryland Court of Appeals Rejects First Amendment Challenge to Local Tax on Outdoor Advertising Services

On February 15, 2021, the Maryland Court of Appeals issued a decision in Clear Channel Outdoor, Inc. v. Director, Department of Finance of Baltimore City, Case No. 24-C-18-001778 (Md. 2021), upholding the constitutionality of...more

New York Law Authorizing Taxation of Spent Nuclear Fuel Storage Facilities Raises Property Tax Issues for the U.S. Nuclear...

A recent change in New York law requires local authorities to assess spent nuclear fuel storage facilities at permanently shutdown nuclear power plants as real property for ad valorem tax purposes. The legislation raises...more

No Sales or Use Tax Due on Materials and Equipment Used to Construct and Install Steam Facility at Tennessee Manufacturing Plant

In a letter ruling published March 16, 2020, the Tennessee Department of Revenue concluded that a contractor’s purchase of materials and equipment for use in the construction and installation of a new steam production...more

Illinois Taxpayers Score Rare TIA Win in Property Tax Dispute

On January 29, 2020, the U.S. Court of Appeals for the Seventh Circuit held the Tax Injunction Act did not bar a federal lawsuit challenging property tax assessments on equal protection grounds because the taxpayers that...more

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