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Local Taxes

Fox Rothschild LLP

IRS Provides Clarification For Business Taxpayers That Make Payments To State Or Local Tax Credit Programs

by Fox Rothschild LLP on

We recently wrote on the new proposed regulations addressing the availability of charitable deductions when taxpayers receive or expect to receive corresponding state or local tax credits for contributions. The proposed...more

Orrick - Structured Finance Group

Treasury Issues Proposed Rule on Charitable Contributions and State and Local Tax Credits

On August 23, 2018, the U.S. Department of the Treasury proposed a “rule on the federal income tax treatment of payments and property transfers under state and local tax credit programs [that] would prevent charitable...more

Fox Rothschild LLP

Treasury Issues Proposed Regulations Addressing Charitable Deductions For State And Local Tax Credit Contributions

by Fox Rothschild LLP on

The Treasury Department recently issued proposed regulations addressing the availability of charitable deductions when taxpayers receive or expect to receive corresponding state or local tax credits for contributions. The...more

Haynsworth Sinkler Boyd, P.A.

IRS Proposed Regulations Erode South Carolina Conservation Easement Tax Credit

On August 23, 2018 the Internal Revenue Service issued Proposed Regulations regarding the $10,000 cap on the deductibility of state and local taxes imposed under the Bipartisan Budget Act of 2018 (Code Section 164(b)(6))....more

Best Best & Krieger LLP

Transfer Of Electric Utility Revenues To City’s General Fund Is Not A Tax Under Proposition 26 - Supreme Court Reverses Court Of...

by Best Best & Krieger LLP on

A city’s annual budgetary transfer from its electric utility to its general fund, referred to as a payment in lieu of taxes and known as PILOT, is an electric utility cost and not an exaction subject to Proposition 26, the...more

Ballard Spahr LLP

IRS Proposes Regulations Disallowing Deductions for Charitable Contributions Paid in Lieu of State and Local Taxes

by Ballard Spahr LLP on

The IRS proposed regulations (the Proposed Regulations) on August 23, 2018, that would largely block state efforts to circumvent new limitations on income tax deductions for state and local taxes and would affect many current...more

Morrison & Foerster LLP

NY Lawsuit Challenging Federal SALT Cap: The Complaint

by Morrison & Foerster LLP on

New York state, together with the states of New Jersey, Connecticut and Maryland, has brought suit in federal district court seeking to invalidate on constitutional grounds the $10,000 cap on state and local tax, or SALT,...more

Morgan Lewis

Four States Sue Federal Government to Invalidate Cap on State and Local Tax Deduction

by Morgan Lewis on

New York, New Jersey, Maryland, and Connecticut are seeking to invalidate the new $10,000 cap on the federal deduction for state and local taxes, alleging that the cap is unconstitutional, interferes with states’ rights to...more

Morrison & Foerster LLP

Pennsylvania: Bonus Depreciation Clarity (Finally!)

by Morrison & Foerster LLP on

On June 28, 2018, the Pennsylvania Legislature enacted legislation allowing companies to depreciate bonus depreciation property placed in service after September 27, 2017 pursuant to the normal federal depreciation rules...more

Cole Schotz

Can Snowbirds Avoid A SALTY Avalanche? Considerations For Changing Residency To The Sunshine State

by Cole Schotz on

There have been sweeping changes to both the federal and New Jersey tax laws for the first half of 2018. At the federal level, the elimination of the state and local tax (SALT) deduction, which for decades allowed people to...more

Fox Rothschild LLP

Four States File Lawsuit Seeking To Invalidate New Federal Cap On State And Local Tax Deduction

by Fox Rothschild LLP on

The States of New York, Connecticut, Maryland, and New Jersey filed a federal court lawsuit this week challenging the constitutionality of the new $10,000 cap on the federal tax deduction for state and local taxes (SALT). The...more

Harris Beach PLLC

New York State among Four States to Sue Federal Government over State and Local Taxes

by Harris Beach PLLC on

Earlier today July 17, 2018 New York State was among four states to sue the federal government over State and Local Tax (SALT) deductions being capped at $10,000 as part of recent federal tax law changes. Joining New York in...more

McDermott Will & Emery

Finishing SALT: June Wrap-Up & Looking at July

by McDermott Will & Emery on

Top June Hits You May Have Missed - BREAKING NEWS: US Supreme Court Overrules Quill - Illinois Budget Bill Makes Few Tax Changes except the Adoption of an Economic Nexus Standard...more

Harris Beach PLLC

In Case You Missed It: 2018 New York Legislative Session Ends Without Traditional "Big Ugly"

by Harris Beach PLLC on

The 2018 legislative session ended late Wednesday, June 20 for the Assembly, and early Thursday, June 21 for the Senate, without the traditional flurry of high profile bills being passed through compromises across the aisle. ...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 9, Issue 7

by Morrison & Foerster LLP on

APPELLATE DIVISION HOLDS THAT BANK MUST APPLY NOLS IN YEAR IT WAS TAXED ON NON-INCOME BASE - The Appellate Division has held that a taxpayer was required to use its net operating loss (“NOL”) carryforward to decrease its...more

Cole Schotz

Governor Murphy’s 2019 Budget: What You Need To Know About The Latest Round Of Tax Hikes

by Cole Schotz on

It was no secret that Governor Murphy ran on a platform heralding an aggressive spending plan of $37.4 billion to fund a lengthy list of entitlements such as hospital and prescription aid, opioid addiction treatment, free...more

Morrison & Foerster LLP

Massachusetts Appellate Tax Board Holds that Corporation Relying on Contract Manufacturing is a Manufacturer Subject to...

by Morrison & Foerster LLP on

The Massachusetts Appellate Tax Board held that a corporation relying on contract manufacturing to produce its products was a “manufacturing corporation” and, therefore, required to use a single-factor apportionment formula...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Update: Early Impact and Trends

Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...more

Morrison & Foerster LLP

Pennsylvania Sales Factor: All Sourcing Leads to Market-Based?

by Morrison & Foerster LLP on

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

McDermott Will & Emery

Circuit Court of Cook County Upholds City of Chicago’s Imposition of Amusement Tax on Internet-Based Streaming Services

by McDermott Will & Emery on

On May 24, 2018, the Circuit Court of Cook County granted the City of Chicago’s Motion for Summary Judgment in the case captioned Labell v. City of Chicago, No. 15 CH 13399 (Ruling), affirming the City’s imposition of its...more

McDermott Will & Emery

Finishing SALT: May Wrap-Up and June Highlights

by McDermott Will & Emery on

Looking Forward to June - June 1, 2018: Stephen Kranz presented “Diverse Routes to Resolving SALT Audit Issues” at the Georgetown Law Advanced State and Local Tax Institute in Washington, DC. Stephen discussed numerous...more

Davis Wright Tremaine LLP

Three Little-Known Features of Seattle’s Head Tax

by Davis Wright Tremaine LLP on

Seattle has passed an employee hours tax, commonly referred to as a “head tax,” which takes effect in 2019. Most are aware that the tax affects corporations, LLCs and LLPs with annual revenues in excess of $20 million...more

Eversheds Sutherland (US) LLP

Chicago streaming video tax does not violate federal and state law

On May 24, 2018, the Circuit Court of Cook County upheld the City of Chicago’s imposition of its amusement tax on streaming services. The plaintiffs in the case—consumers of streaming services—are expected to appeal the...more

Bond Schoeneck & King PLLC

Uncertainty Surrounding SALT Deduction Workarounds

by Bond Schoeneck & King PLLC on

In the wake of federal tax reform, i.e., the passage of the Tax Cuts and Jobs Act of 2017 (the “Tax Act”), specifically, the new $10,000 cap on itemized deductions for state and local taxes (i.e., SALT deductions), several...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Notice on Payments Made in Exchange for State and Local Tax Credits

On May 23, 2018, the Department of the Treasury and the Internal Revenue Service (IRS) issued Notice 2018-54, stating that proposed regulations will be issued addressing the deductibility of certain payments made by taxpayers...more

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