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Department of Revenue

Blank Rome LLP

Washington Court Denies B&O Tax Refund to IT Company in Apportionment Dispute

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In Valente Solutions, LLC v. Department of Revenue, the Washington Court of Appeals addressed whether an information technology consulting firm was entitled to a refund of Washington business and occupation (“B&O”) taxes for...more

Baker Donelson

Tennessee Department of Revenue Releases New Informal Conference Decision Summaries

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Summaries Released of Select Informal Conference Decisions: The Tennessee Department of Revenue (Department) recently posted certain selected informal conference summaries, which provide taxpayers with insight into how the...more

Husch Blackwell LLP

Illinois Rules that Sales Tax Applies to Equipment Used to Produce RNG

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Like many states, Illinois provides an exemption to its Retailers Occupation Tax (sales tax) for machinery and equipment primarily used in a manufacturing operation. However, that exemption does not extend to machinery and...more

Bradley Arant Boult Cummings LLP

Alabama DOR Issues Guidance Regarding New Postmark Procedures Impacting Time-Sensitive Filings

The Alabama Department of Revenue (“AL DOR”) published helpful guidance on January 28 regarding “recent updates to the United States Postal Service (“USPS”) procedures that may affect postmark dates on mailed tax returns,...more

Maynard Nexsen

SC Alcohol Law Update | Server Training Approved

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New Update: Required Server Training Programs Approved Under New Law - The DOR has now approved server training programs under H.3430. These programs are available for registration at dor.sc.gov/abl-server-training....more

Husch Blackwell LLP

New Hampshire Establishes Amnesty Program for Taxpayers

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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

Rivkin Radler LLP

Escape from New York – It’s Not That Easy

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It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more

Blank Rome LLP

Florida Court Directs Department to Pay Up

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When a taxpayer succeeds on a refund claim they are often entitled to interest on such refund. Unfortunately, departments of revenue sometimes take unlawful steps to prevent taxpayers from recouping such amounts. A recent...more

Blank Rome LLP

The Future of Public Law 86-272

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The Massachusetts Department of Revenue (“MA DOR”) recently joined its counterparts in New York and New Jersey in formally promulgating regulatory amendments adopting aspects of the 2021 revised guidance approved by the...more

Blank Rome LLP

Wet Yard, Dry Record: Alabama Taxpayer’s Refund Claim Denied for Lack of Proof

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In a decision issued on October 23, 2025, the Alabama Tax Tribunal (the “Tribunal”) denied Alabama Chips, Inc.’s (“Alabama Chips”) refund claim for sales tax paid on certain heavy equipment. The case centered on whether...more

Husch Blackwell LLP

Illinois DOR Clarifies Application of New Tax on Pre-2025 Operating Leases

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Effective January 1, 2025, Illinois’ Public Act 103-592 changed how the state taxes operating leases. Prior to this change, Illinois did not tax receipts from the lease of tangible personal property. Instead, lessors were...more

Husch Blackwell LLP

North Carolina Supreme Court Holds De Novo Review Required in Interpreting Agency Rules

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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

Bradley Arant Boult Cummings LLP

Alabama Department of Revenue Issues Helpful Analysis of Impact of OBBBA on Alabama Income Tax Code

As readers may recall, on July 4, 2025, President Trump signed into law the massive One Big Beautiful Bill Act (OBBBA) as Public Law 119-21, which made permanent many provisions of the Tax Cuts and Jobs Act of 2017. OBBBA...more

DarrowEverett LLP

Massachusetts Real Estate Transfers Over $1M Face New Tax Rules

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Attention to owners of real estate in the Commonwealth (and the title companies and other professionals who advise them), the Massachusetts Department of Revenue (the “DOR”) recently adopted a new “millionaire’s tax” via 830...more

Ballard Spahr LLP

Trick or Treat? October 31 Deadline for Washington State Tax Approaches

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Welcome, taxpayers and soon-to-be trick-or-treaters, to our annual Washington State October 31 reconciliation reminder....more

Pierce Atwood LLP

Maine Governor Janet Mills Provides Temporary OBBBA Conformity Directions

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Maine currently conforms to the Internal Revenue Code in effect as of December 31, 2024. As a result, none of the numerous federal tax changes enacted in the One Big Beautiful Bill Act (OBBBA) have been incorporated in Maine...more

Husch Blackwell LLP

Alabama Tax Ruling Holds That Fiber Optic Cable Is Not a Machine

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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

Husch Blackwell LLP

Minnesota Supreme Court Rules on Sourcing Pharmacy Benefit Management Services

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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

McDermott Will & Schulte

Washington DOR issues interim guidance on advertising services

The Washington Department of Revenue (DOR) released an Interim Guidance Statement (IGS) on Advertising Services implementing Engrossed Substitute Senate Bill (ESSB) 5814 ahead of the October 1, 2025, effective date. In...more

Shipman & Goodwin LLP

2025 Connecticut Tax Developments

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In its 2025 regular and special sessions, the General Assembly made a number of changes to the statutes that affect Connecticut taxes. This newsletter summarizes Connecticut tax legislation enacted, court decisions rendered,...more

Cozen O'Connor

Exception to General Refund Limitations Period for PA Corporate Net Income Tax for Report of Change

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In an unusually taxpayer-friendly decision, a three judge panel of the Pennsylvania Commonwealth Court concluded that Section 406 of the Tax Reform Code of 1971 (the code), 72 P.S. § 7406, is an exception to the general...more

McDermott Will & Schulte

Generative AI chatbot service not subject to Indiana sales tax

In one of the first pieces of administrative guidance addressing the sales tax treatment of generative artificial intelligence (AI) services, the Indiana Department of Revenue (DOR) recently issued a revenue ruling confirming...more

Lasher

Family Investment Vehicles in Limbo: Awaiting Department of Revenue Guidance

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The legal landscape for family investment vehicles in Washington shifted dramatically after the Antio LLC v. Department of Revenue decision of the Washington Supreme Court. In Antio the taxpayers were a group of investment...more

Ballard Spahr LLP

Big Changes to Washington State Department of Revenue’s Voluntary Disclosure Agreement (VDA) Program

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At last week’s Washington State Tax Forum, the Washington Department of Revenue announced, in a presentation led by Ballard Spahr’s Aaron Johnson, that the Department is making significant and meaningful changes to its...more

McDermott Will & Schulte

Washington’s advertising services tax: Sourcing rules clear as mud

Washington’s sales tax on advertising services takes effect October 1, 2025, and comes in two forms: a tax on digital automated services and a tax on retail sales of advertising services. Both impositions apply to digital...more

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