Things have been heating up this summer. Let’s see what’s been cooking with the Texas Comptroller’s office....more
The recent Tax Court case of Kohout v. Commissioner addresses several common evidentiary issues in the context of tax disputes. A summary, chart, or calculation to prove the content of voluminous records may be appropriate...more
The Tax Court in Brief – February 28th-March 4th, 2022 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. ...more
Oregon State Senator Fred Girod, a Republican from Stayton, Oregon (District 9), is sponsoring Senate Bill 787 ("SB 787"). If passed, SB 787 would repeal the Oregon Corporate Activity Tax (the "CAT"). So far, the bill does...more
In mid-January, the Texas Comptroller issued controversial amendments to its franchise (margin) tax apportionment sourcing rules. Are the rules an administrative drift towards market-based sourcing? Matt Hunsaker breaks down...more
This article is the first of a three-part series regarding the State and Local Tax consequences of doing business in multiple states. Part 1 will discuss Nexus, Part 2 will discuss Voluntary Disclosures, and Part 3 will...more
Throughout November, various Multistate Tax Commission committees held virtual annual meetings (due to COVID). In this episode, Matt Hunsaker runs down the highlights from each meeting, including technical corrections to...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
A common question in many Ohio commercial activity tax (CAT) audits is whether federal tax treatment may be relied upon. Although the statute says it should (R.C. 5751.01(K)), the Tax Commissioner is often reluctant to accept...more
A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more
New York state legislators recently introduced legislation loosely proposing to impose a five percent gross receipts tax on data sharing. The legislation says little about how the tax will work, but it has gained the...more
As the economy shifts to a digital one, we are finding that states are turning toward unconventional revenue options. One trend we’re seeing is the surprising comeback of the gross receipts tax (GRT): • Oregon’s new...more
We have recently discussed in several blog posts Oregon’s new Corporate Activity Tax (“CAT”), a gross receipts tax that will become effective January 1, 2020. As we announced in our most recent post on this topic, the Oregon...more
The San Francisco Gross Receipts Tax (GRT) incorporates provisions of both the federal income tax and the California income and franchise tax. Taxpayers should review their federal and California tax reporting that may impact...more
Fund Managers May Be Taxable in California, Even if the Manager Has No Property or Payroll in California and All of the Management Services Are Performed Outside of the State. Several recent law changes in California,...more
The recently concluded 2013 regular session of the New Mexico Legislature resulted in legislation enacting several significant changes to New Mexico’s tax programs, the majority of which are business friendly. Most of the...more