Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Videocast: 2020 – The year of digital taxation
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
Welcome to Nutter's Beverage Breakdown, a periodic legal update on noteworthy developments related to the alcohol beverage industry, including industry news, federal and state updates, and more. ...more
A New York State Administrative Law Judge (“ALJ”) recently rejected an attempt by the Division of Taxation (“Division”) to change its theory of liability after the record was closed, raising its new theory of liability for...more
In the latest but likely not final chapter of Professor Zelinsky’s ongoing challenge to New York’s convenience of the employer rule, a New York Administrative Law Judge ("ALJ") upheld application of the rule, counting days...more
Howdy folks, and welcome back to another edition of the Texas Tax Roundup, where we gab about all things Texas tax and perhaps even some things Texas tax adjacent. As ole T.S. once put it, “April is the cruelest...more
Franchise Tax - Apportionment - 34 Tex. Admin. Code § 3.591 (Margin: Apportionment)—The Comptroller adopted his amendments outlined in our previous post to implement the Texas Supreme Court’s opinion in Sirius XM...more
An Administrative Law Judge (“ALJ”) recently found that a taxpayer’s vendor and labor management services, which were provided in conjunction with the grant of a software license, were subject to sales tax as the sale of...more
An Administrative Law Judge (“ALJ”) recently determined that an individual member of a limited liability company (“LLC”) was personally liable for an LLC’s sales tax deficiency, both because he was a member of the LLC, and...more
December was a bit of a slow month on the Texas tax front. Hopefully everyone was out of their respective offices and enjoying the holidays/resting up for the upcoming legislative session. Still, we got an interesting opinion...more
An Administrative Law Judge (“ALJ”) recently issued a determination cancelling the notices of determination issues by the New York State Department of Taxation and Finance and finding that the taxpayer’s e-mail tracking and...more
An administrative law judge in the New York State Division of Tax Appeals rejected the state’s position that a taxpayer providing a web-based service which allowed clients to identify effective and ineffective messaging...more
Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more
Huh whuh? . . . Well . . . Well, howdy! Nice, erm, um well . . . Nice to see ya’ll again at or near this nebulous home home on the range of Texas taxability! Welcome back to another tax-packed installment of all things Texas...more
The New York State Tax Appeals Tribunal held that an information service was not subject to sales tax because although the service provider had the right to provide the information to others, it did not have the technical...more
Hiya folks, and welcome to the inaugural installment of our new series giving you a quick recap of what’s happened in the world of Texas taxes in the month gone by. Let’s get started!...more
Two recent New York State decisions illustrate the importance of the “primary function” test for determining taxability under the New York State sales tax, in both cases involving the tax on information services. Applying...more
A year and a half following the New York Court of Appeals’ significant 2019 decision in Matter of Wegmans Food Markets, Inc. v. Tax Appeals Tribunal of State of New York, 33 NY3d 587 (2019), New York continues to grapple with...more
Welcome to the latest issue of New York Tax Insights. In this issue we cover: • Our annual review of the developments we considered the Top 10 New York tax highlights in the past year (on page 1). •Three separate ALJ...more
FEDERAL JUDGE DISMISSES NEW YORK STATE LAWSUIT CHALLENGING $10,000 SALT DEDUCTION CAP - A federal district court judge has dismissed a suit brought by New York State (together with Connecticut, New Jersey, and Maryland)...more
Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..A recent ALJ decision holding that a vacation home owned by a New Jersey domiciliary and located in upstate New York, hundreds of miles from...more
TRIBUNAL AFFIRMS DECISION SOURCING “OTHER BUSINESS RECEIPTS” TO WHERE THE WORK WAS PERFORMED - After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new...more
Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..A Third Department decision denying deductibility of insurance premiums paid to a captive insurance company, upholding the decision of the New...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
TRIBUNAL REMANDS $100 MILLION SALES TAX REFUND CASE TO ALJ - After the New York State Appellate Division reversed the Tax Appeals Tribunal’s earlier decision denying a sales tax refund of over $100 million, the Tax...more
Appellate Court Holds That Furnishing of Pricing Information Is Not a Taxable Information Service - The Appellate Division has issued a potentially important decision regarding the sales tax exclusion for information...more
Securities Rating Agency Not Entitled to Refund of Erroneously Remitted Sales Tax - A New York State Administrative Law Judge upheld the denial of a securities rating agency’s request for a refund of sales tax, holding...more