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Department of Revenue Internal Revenue Code (IRC)

Ogletree, Deakins, Nash, Smoak & Stewart,...

Reminder: Dependent Care Assistance Is Now Excludable in Pennsylvania, Retroactive to 2023 Tax Year

With tax day quickly approaching on April 15, 2024, employers in Pennsylvania may want to take note of a December 2023 state tax law that might have flown under the radar. The law made employee contributions to...more

Eversheds Sutherland (US) LLP

Florida District Court of Appeals hears oral arguments in addback dispute

​​​​​​​On October 11, 2022, the Florida District Court of Appeals, First District held oral arguments on State Farm Mutual Automobile Insurance Company v. Florida Department of Revenue, a case relating to the “add back” to...more

Tucker Arensberg, P.C.

Pennsylvania Personal Income Tax Will Follow Federal Rules for Like Kind Exchanges under Internal Revenue Code Section 1031 for...

The accounting rules for the Pennsylvania Personal Income Tax do not follow the Federal Tax Code. Instead, they follow generally accepted accounting principles....more

Schwabe, Williamson & Wyatt PC

Enactment of SB 164 and Changes to Oregon's Corporate Activity Tax

Although Oregon’s 2021 legislative session turned out to be relatively quiet from a tax perspective, we did experience some changes to Oregon’s Corporate Activity Tax (“CAT”). Those changes were primarily in the form of SB...more

Bradley Arant Boult Cummings LLP

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called “SALT Cap” enacted as part of the Tax Cuts and Jobs Act of 2017 that limits the deductibility of...more

Bradley Arant Boult Cummings LLP

ADOR Issues Guidance on New PTE Tax Election and Consequences of Decoupling from GILTI and IRC §118(b)(2)

At the urging of the Alabama Society of CPAs and other groups, the Alabama Department of Revenue (ADOR) recently issued preliminary guidance on (a) how the new pass-through entity (PTE) tax election interacts with the...more

Foster Garvey PC

The Oregon Department of Revenue Held Its CAT Call as Scheduled – The Business and Tax Community Were Represented

Foster Garvey PC on

As we reported last week, the Oregon Department of Revenue (“DOR”) scheduled a public hearing on June 23, 2020 to discuss the second set of temporary administrative rules relative to the Oregon Corporate Activity Tax (the...more

McDermott Will & Emery

IRS Flexes Its Administrative Summons Power in Recent Tax Case

McDermott Will & Emery on

The United States Court of Appeals for the Tenth Circuit’s recent opinion in Standing Akimbo, LLC v. United States, No. 19-1049 (10th Cir. April 7, 2020), reminds us of the Internal Revenue Service’s (IRS) ability to obtain...more

Bradley Arant Boult Cummings LLP

Legislative Task Force on the Impact of the Tax Cuts and Jobs Act Releases Its Final Report - SALT Alert: Alabama Edition

The Alabama Legislature was stymied last year over proposals to decouple from or conform with various provisions of the Tax Cuts and Jobs Act of 2017 (TCJA). As a compromise, the Legislature formed a Joint Legislative Task...more

Foster Garvey PC

Oregon’s New Corporate Activity Tax

Foster Garvey PC on

We are taking a break from our multi-post coverage of Opportunity Zones to address a recent, significant piece of Oregon tax legislation. On May 16, 2019, Governor Kate Brown signed into law legislation imposing a new...more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Bradley Arant Boult Cummings LLP

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part X: Oregon Disconnects from IRC Section 199A

Foster Garvey PC on

As we have been discussing these past several weeks, the Tax Cuts and Jobs Act (“TCJA”) drastically changed the Federal income tax landscape. The TCJA also triggered a sea of change in the income tax laws of states like...more

McDermott Will & Emery

Illinois Confirms Treatment of Deemed Repatriated Foreign Earnings Provisions

McDermott Will & Emery on

On Wednesday, the Illinois Department of Revenue (Department) issued additional guidance concerning its treatment of the new deemed repatriated foreign earnings provisions found in Internal Revenue Code Section 965, enacted...more

McDermott Will & Emery

SALT Implications of Proposed Section 385 Debt/Equity Regulations

McDermott Will & Emery on

Determining the difference between debt and equity is a problem that has bedeviled taxpayers and tax administrators for decades. Taxpayers, recognizing that there are tax advantages to financing a corporation with debt (e.g.,...more

Morrison & Foerster LLP

Out-of-State Subsidiary Holding Company Cannot Be Forcibly Included in a Colorado Combined Return

A Denver District Court judge has held that the Colorado Department of Revenue cannot forcibly combine a corporation’s subsidiary, a holding company that derived its income solely from investments in foreign entities, in...more

Baker Donelson

Spotlight On Alabama: A Busy Tax Year in Review

Baker Donelson on

It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more

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