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Zachary Atkins

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

Business Taxes, Income Taxes, New Jersey, State and Local Government, Tax Court

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Craig Becker

California Lawmakers Propose Constitutional Amendment to Abolish the State Board of Equalization

California Democratic lawmakers recently introduced Assembly Constitutional Amendment 11 (“ACA 11”) which proposes to abolish the State Board of Equalization (“BOE”) and reassign its responsibilities to other state tax agencies…more

Board of Equalization, Constitutional Amendment, Property Tax, Tax Assessment

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Jack Camillo

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

Business Taxes, Income Taxes, New Jersey, State and Local Government, Tax Court

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Joseph Chan

Minnesota Tax Court Denies a Catalog and Internet-Based Distribution Company Public Law 86-272 Protection

The Minnesota Tax Court held a catalog and internet-based distribution company exceeded the protections of Public Law 86-272 (PL 86-272) by providing non-sales personnel with information about competitors’ products and sales…more

Income Taxes, State Taxes, Tax Court

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Aruna Chittiappa

Big Things Have Small Beginnings: New Jersey Broadens Definition of Unitary Business

On July 3, 2023, Governor Phil Murphy signed into law A.B. 5323, enacting important revisions to New Jersey’s Corporation Business Tax (CBT) including expanding the definition of what constitutes a “unitary business.” The…more

Business Taxes, Corporate Taxes, New Jersey

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Evan Hamme

New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operating Location

The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the…more

Administrative Law Judge (ALJ), Income Taxes, New York, Partnerships, Tax Liability

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Annie Huang

Hidden Within the Transparency and Fairness Act of 2017 was the Little Noticed Exemption from OAL Review of the CDTFA’s Proposed Regulations

Much to the recent surprise of many in the tax community, the California Department of Tax and Fee Administration (“CDTFA”) is able to adopt or amend regulations without the normal review process by the Office of Administrative…more

Administrative Procedure Act, California, Office of Administrative Law

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Nolan Kessler

Reminder: “Gross” Does Not Mean “Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor

In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator…more

Apportionment, California, Dividends, Income Taxes, Sales Factor

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Christopher Koester

New York Administrative Law Judge Holds ITFA Preempts Taxation of Gross Receipts From ADSL and Fiber Broadband Sales

An administrative law judge with the New York State Division of Tax Appeals held that the federal Internet Tax Freedom Act (ITFA) preempted the imposition of New York franchise tax and a metropolitan transportation business tax…more

Broadband, Franchise Taxes, Gross Receipts Tax, Internet Service Providers (ISPs), Internet Tax Freedom Act

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Robert Merten III

Carveouts Count! Taxpayer Wins New Mexico Statutory Carveout Issue Regarding Unity

The New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carveout language regarding the term…more

Dividends, Foreign Corporations, Foreign Subsidiaries, Oil & Gas, Tax Returns

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Richard Nielsen

Proposed Initiative to Amend San Francisco Business Taxes

A proposed initiative is being circulated to place on the November 5, 2024 ballot, an ordinance amending the Business and Tax Regulations Code effective January 1, 2025…more

Ballot Measures, Business Taxes, California, Exemptions, Gross Receipts Tax

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Jeff Phang

California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization

The May Revision of California’s 2024-2025 state budget seeks to block refund claims, worth approximately $1.3 billion for historical tax years, and $200 million per year going forward, by codifying informal guidance recently…more

Administrative Procedure Act, Franchise Tax Board, Income Taxes, SALT, State Budgets

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Carley Roberts

California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization

The May Revision of California’s 2024-2025 state budget seeks to block refund claims, worth approximately $1.3 billion for historical tax years, and $200 million per year going forward, by codifying informal guidance recently…more

Administrative Procedure Act, Franchise Tax Board, Income Taxes, SALT, State Budgets

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Breann Robowski

California Lawmakers Propose Constitutional Amendment to Abolish the State Board of Equalization

California Democratic lawmakers recently introduced Assembly Constitutional Amendment 11 (“ACA 11”) which proposes to abolish the State Board of Equalization (“BOE”) and reassign its responsibilities to other state tax agencies…more

Board of Equalization, Constitutional Amendment, Property Tax, Tax Assessment

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Kristen Sharp

California Lawmakers Propose Constitutional Amendment to Abolish the State Board of Equalization

California Democratic lawmakers recently introduced Assembly Constitutional Amendment 11 (“ACA 11”) which proposes to abolish the State Board of Equalization (“BOE”) and reassign its responsibilities to other state tax agencies…more

Board of Equalization, Constitutional Amendment, Property Tax, Tax Assessment

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Marc Simonetti

Three Strikes, You’re Out! New York Has Another Miss in Sales Tax Case Against a Service Provider Under the “Primary Function” Test

An administrative law judge (“ALJ”) in the New York State Division of Tax Appeals cancelled the New York State Division of Taxation’s notice of determination asserting sales tax on petitioner’s verification services. The…more

New York, Sales & Use Tax, Sales Tax, State Taxes

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Jeffrey Vesely

California’s 2024-2025 Budget Seeks to Block $1.3 Billion of Refunds for Water’s Edge Taxpayers, Suspend NOL Deductions, and Limit Tax Credit Utilization

The May Revision of California’s 2024-2025 state budget seeks to block refund claims, worth approximately $1.3 billion for historical tax years, and $200 million per year going forward, by codifying informal guidance recently…more

Administrative Procedure Act, Franchise Tax Board, Income Taxes, SALT, State Budgets

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Taylor A. F. Wolff

Carveouts Count! Taxpayer Wins New Mexico Statutory Carveout Issue Regarding Unity

The New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carveout language regarding the term…more

Dividends, Foreign Corporations, Foreign Subsidiaries, Oil & Gas, Tax Returns

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Breanna Zagorski

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. These…more

Apportionment, Corporate Taxes, Income Taxes, New Legislation, State and Local Government

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