In 2021, the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The Alabama Electing...more
During the 2022 legislative session, the Georgia General Assembly passed significant tax legislation, including authorizing affiliated groups to file consolidated corporate income tax returns without prior approval from the...more
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
During the 2021 legislative session, the Georgia General Assembly passed key legislation, including conformity to the federal tax law, the elimination of deference to subregulatory interpretations of the Department of...more
A new Massachusetts Department of Revenue (DOR) Report to the Legislature supports changing the Commonwealth’s tax law to enable owners of partnerships and S corporations to avoid the federal limitation on state and local tax...more
On December 11, 2020, Massachusetts Governor Charlie Baker signed the Commonwealth’s FY21 budget into law. While the $45.9 billion budget does not raise taxes, it includes a number of significant tax provisions summarized...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
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
Bedliner Chemicals Represent a Taxable Sale to the Franchisee Rather than to the Customer - For those of you with bedliners in your trucks or other vehicles, a recent decision from the Alabama Tax Tribunal indicates you...more
In a 5-3-1 decision, the Alabama Supreme Court ruled on Friday that the sale of computer software in Alabama is subject to sales or use tax, even if it’s customized in whole or in part for a particular user (see Ex parte...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
In a case of first impression by an Alabama appellate court, the Alabama Court of Civil Appeals recently considered the appeal of the Alabama Department of Revenue (ADOR) of an adverse circuit court ruling involving whether...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
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
During the 108th General Assembly 2014 Session, the Tennessee Legislature considered several tax and related initiatives before adjourning in late April. Although the number of proposed tax and related initiatives this...more
The Tennessee Department of Revenue has issued Notice 13-06 to clarify the tax treatment of single-member limited liability companies (SMLLCs) owned by entities checking the box to be treated as corporations for federal tax...more