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Administrative Law Judge (ALJ) Sales & Use Tax

Blank Rome LLP

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

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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

Freeman Law

Texas Tax Roundup | March 2023: Flowback, Welding, Local Taxes, and More!

Freeman Law on

Franchise Tax - Apportionment - 34 Tex. Admin. Code § 3.591 (Margin: Apportionment)—The Comptroller adopted his amendments outlined in our previous post to implement the Texas Supreme Court’s opinion in Sirius XM...more

Freeman Law

Texas Tax Roundup | January 2023

Freeman Law on

Hiya, folks and welcome back to a whole new edition (in a whole new year) of the Texas Tax Roundup! January started the year off with a blast! Let’s see what happened!   Sales and Use Tax  Governmental Exemption...more

Freeman Law

Texas Tax Roundup | November 2022: What’s a Franchise Tax?

Freeman Law on

Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more

Pillsbury - SeeSalt Blog

“Primary Function” Test Propels Yet Another Service Provider to Victory in New York Sales Tax Case

Pillsbury - SeeSalt Blog on

An administrative law judge in the New York State Division of Tax Appeals rejected the state’s position that a taxpayer providing a web-based service which allowed clients to identify effective and ineffective messaging...more

Freeman Law

Texas Tax Roundup | February 2022 (RECOVERED!)

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Howdy y’all!  Has it been a month already?  We’ve got another action-packed month of Comptroller-related news.  Here we go! Court Cases Courts of Appeals Hegar v. Black, Mann, and Graham, L.L.P., No. 03-20-00391-CV (Tex....more

Freeman Law

Texas Tax Roundup | March 2022

Freeman Law on

Huh whuh? . . . Well . . . Well, howdy! Nice, erm, um well . . . Nice to see ya’ll again at or near this nebulous home home on the range of Texas taxability! Welcome back to another tax-packed installment of all things Texas...more

Freeman Law

Texas Tax Roundup—January 2022

Freeman Law on

Hiya folks, and welcome to the inaugural installment of our new series giving you a quick recap of what’s happened in the world of Texas taxes in the month gone by. Let’s get started!...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 8

Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..The New York State Department of Taxation and Finance’s release of revisions to its draft business corporate franchise tax regulations for...more

Dorsey & Whitney LLP

The Supreme Court - June 21, 2018

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The Supreme Court of the United States issued four decisions today: Lucia v. SEC, No. 17-130: The Securities and Exchange Commission (“SEC”) is statutorily authorized to institute administrative proceedings against...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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A couple of big-time SCOTUS opinions released yesterday will leave their mark on the financial world— First, the High Court found that internet retailers can be “required to collect sales taxes in states where they have no...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

Burr & Forman on

There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 9, Issue 2

2018–19 NEW YORK STATE EXECUTIVE BUDGET RELEASED - New York State Governor Andrew M. Cuomo has released the New York State 2018-2019 Executive Budget, containing several potentially significant tax proposals. They include...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 10

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Tribunal Reverses ALJ and Holds that Department Impermissibly Discriminated Against Foreign Unauthorized Insurance Corporations - In an issue of first impression in New York, the New York State Tax Appeals Tribunal has...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 12

NYC ALJ Holds That Consulting Firm May Source Receipts Based on Location of Independent Contractors - The nature of the services performed by a corporation, and how that corporation should source its receipts from those...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 11

ALJ Permits Only Minimum Penalties for Failure to File Information Returns - A New York State Administrative Law Judge has rejected the maximum penalties imposed by the Department of Taxation and Finance on an...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 10

Recent unpublished NYC Department of Finance Letter Rulings - We have obtained under the Freedom of Information Law several Finance Letter Rulings of interest, most involving the New York City real property transfer tax,...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 4

ALJ holds that Insurance Payments to Captive Insurance Company Are not Deductible - In Matter of Stewart’s Shops Corp., DTA No. 825745 (N.Y.S. Div. of Tax App., Mar. 10, 2016), a New York State Administrative Law Judge...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 5, Issue 6 - June 2014

In This Issue: - New York Court Grants Airbnb’s Motion to Quash Attorney General’s Subpoena - New York City UBT Ruling Allows Broker-Dealer Sourcing for Non-Registered Broker-Dealers - ALJ Dismisses Action as...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 4, Issue 1 - January 2013

In This Issue: Court of Appeals Reverses Appellate Division, Holds that EchoStar’s Equipment Purchases Qualified as Sales for Resale; Appellate Court Holds Electronic Messaging Services Subject to Sales Tax; ALJ Finds...more

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