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, which limits the deductibility of...more
The Wisconsin Court of Appeals, District IV, issued its decision in Wisconsin Department of Revenue v. Deere & Company, regarding the treatment of distributions from foreign partnerships that are treated as corporations for...more
In the wake of the coronavirus pandemic, companies in wide-ranging industries across the country have unprecedented numbers of employees working from remote locations. In a prior post, we discussed numerous issues that may...more
On January 6, I presented a new White Paper, The Oregon Corporate Activity Tax – You Can Run and You Can Hide, but This New Tax Is Effective January 1, 2020, at the Oregon Society of Certified Public Accountants Annual State...more
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
In a case of first impression, an Alabama circuit court recently ordered a taxpayer to pay the auditing fees that a private auditing firm normally would charge to its local government clients. Initially, the court ordered the...more
The Massachusetts Department of Revenue (“Department”) recently promulgated a proposed amended regulation governing the classification of corporations as “manufacturing corporations” for corporate excise tax purposes (the...more
Words Matter: Complying with State Tax Laws - Statutes mean what they say. As the late Justice Scalia once quipped, the proper role of the courts “is to apply the text, not to improve upon it.” However, revenue departments...more
The Pennsylvania Department of Revenue (the “Department”) has been taking aggressive positions to source sales of services to Pennsylvania for corporate tax purposes. For tax years beginning on or prior to December 31, 2013,...more
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
The Virginia Supreme Court granted the Company’s petition for rehearing and confirmed that the Department of Revenue’s interpretations that are not contained in regulations are entitled to no weight. ...more
Last year, Illinois enacted a mid-year income tax rate increase. Effective July 1, 2017, Illinois increased the income tax rate for individuals, trusts and estates from 3.75 percent to 4.95 percent, and for corporations from...more
The Illinois Department of Revenue (Department) has issued a proposed new administrative rule addressing the nexus implications for out-of-state retailers attending trade shows in Illinois. The proposed rule reaffirms the...more
May 16, 2017: Illinois Department of Revenue Affirms Cloud-Based Services Not Taxable - In two recent General Information Letters (GILs), the Illinois Department of Revenue (Department) reaffirmed that computer software...more
Yesterday afternoon, the Alabama Department of Revenue (ADOR) withdrew its controversial proposed digital tax regulation, Rule 810-6-5-09, likely in response to the request of the Legislative Council’s newly-appointed...more