California’s Existing Partial Exemption for Statewide Sales and Use Tax Paid on Qualified Tangible Personal PropertyRTC section 6377.1 exempts from certain state sales and use taxes the sale of, and the storage, use or other...more
On May 4, 2023, Indiana Governor Eric Holcomb signed legislation (Laws 2023, SB419) that, among other tax changes, included provisions to exempt from income tax nonresidents receiving compensation for employment duties...more
In 2021, Washington State Legislature passed ESSB 5096, which created a 7% tax on the sale or exchange of long-term capital assets (stocks, bonds, business interests, or other investments, and many tangible assets) if the...more
“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more
South Carolina imposes sales tax on retail sales of tangible personal property. South Carolina generally does not impose a sales tax on intangible property, however, certain intangible property is deemed to be tangible...more
A dog will immediately respond to you when you call out. On the other hand, when you call out to a cat, the cat will take a message and promise to get back to you later. This is not the case with the Corporate Activity Tax...more
On October 31, 2019, the Wisconsin Court of Appeals rejected the Wisconsin Department of Revenue’s (DOR) position in Wisconsin Department of Revenue v. Microsoft Corporation, Case No. 2018AP2024 that Microsoft should “look...more
Congress enacted the Opportunity Zone (“OZ”) investment incentives in late 2017 as part of the Tax Cuts and Jobs Act. Since then many investors, fund managers, and community development professionals have devoted significant...more
Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more
The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more
As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more
On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more
BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more
The Treasury Department and Internal Revenue Service issued proposed regulations and other guidance on the new "opportunity zone" tax incentive on October 19, 2018. This tax incentive encourages investment in certain...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
As previously reported, during the recent legislative session the Alabama Legislature finally resolved the so-called “Moody Issue,” named after the taxpayer victory in Moody v. Alabama Department of Revenue, regarding the...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
An IRS tax levy is a seizure of a person’s property or rights to property. The IRS then uses the seized property to pay taxes owed. A levy allows the IRS to confiscate a person’s property, which includes cars, boats, real...more
In early November, I posted an article entitled “Tax Reform Proposal Nixes Favorable Tax Treatment of Several Employee Benefits”. That article reviewed the Ways and Means Committee’s proposal (H.R. 1, the Tax Reform and Jobs...more
Originally published in State Tax Notes. Many states have created special treatment for manufacturers, including tax exemptions, credits, and special income tax apportionment rules. In this edition of A Pinch of SALT, we...more