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Welcome to the January 2026 edition of The BR State + Local Tax Spotlight. We know the importance of remaining up-to-date on State + Local Tax developments, which appear often and across numerous jurisdictions. ...more
In Valente Solutions, LLC v. Department of Revenue, the Washington Court of Appeals addressed whether an information technology consulting firm was entitled to a refund of Washington business and occupation (“B&O”) taxes for...more
The recent decision of the United States Court of Federal Claims in Kwong v. United States, No. 23-267 (Fed. Cl. Nov. 25, 2025), provides a potential tax refund opportunity for taxpayers who paid underpayment interest and/or...more
Over the course of a few weeks, the Ohio Supreme Court has released a pair of decisions that offer guidance on how to determine the situs of gross receipts for purposes of calculating the Commercial Activity Tax (CAT) as well...more
By any measure, 2025 was a tumultuous year for the Internal Revenue Service (IRS), leaving a slimmed-down organization struggling to implement new priorities and a workforce trying to catch its breath in the face of dizzying...more
In a January 14, 2026 opinion, the Ohio Supreme Court denied an apparel company’s $855,000 refund claim for Ohio’s commercial activity tax (CAT) for tax years 2010 through 2016. ...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 15, 2025 – December 22, 2025....more
Two developments are converging that could reshape how Section 280E applies to cannabis businesses. The Tax Court is considering a case that raises whether a change in marijuana’s federal scheduling could have retroactive...more
The Pennsylvania Commonwealth Court’s decision in 430 Stump Road, LLP v. Commonwealth marks a significant clarification for transactions involving real estate companies and Pennsylvania’s realty transfer tax. The ruling...more
State procedures for obtaining refunds of sales tax can be difficult to navigate for both purchasers and sellers. A recent decision of the Alabama Tax Tribunal involving the statute of limitations for refunds reasonably...more
In 2018, the Alabama Legislature passed Alabama Act 2018-180, which changed the procedure for consumers petitioning for refunds of Utility Gross Receipts Tax (UGRT), sales or use tax, or transient occupancy tax. Prior to Act...more
Taxpayers who paid the stock repurchase excise tax based on prior guidance provided in Notice 2023-2 and the proposed regulations under Internal Revenue Code (IRC) § 4501 may be entitled to a refund based on changes made in...more
The 2026 Budget Bill aims to implement the Mediolanum ruling of the Court of Justice of the European Union (CJEU, 1 August 2025). The ruling looked at the IRAP regime applicable to banks, financial intermediaries and...more
The US Court of Federal Claims’ (CFC) recent decision in Kwong v. United States, No. 23-267 (Fed. Cl. Nov. 25, 2025), provides significant support for the potential refund opportunity we identified in a previous blog post...more
The U.S. government has issued final regulations significantly limiting the situations where a corporation will be liable for the 1% corporate stock buyback tax applicable to public companies. The Situation: Taxpayers...more
The longest recorded government shutdown is finally over. As many government agencies return to normal business operations, many small business owners still have one burning question: how do I get my employee retention credit...more
When a taxpayer succeeds on a refund claim they are often entitled to interest on such refund. Unfortunately, departments of revenue sometimes take unlawful steps to prevent taxpayers from recouping such amounts. A recent...more
In a decision issued on October 23, 2025, the Alabama Tax Tribunal (the “Tribunal”) denied Alabama Chips, Inc.’s (“Alabama Chips”) refund claim for sales tax paid on certain heavy equipment. The case centered on whether...more
The Shutdown & the IRS: What is Going On - When Congress fails to pass appropriation bills or a continuing resolution, non‑essential federal operations are forced to pause. The Internal Revenue Service (“IRS”) is no...more
The Spanish Supreme Court (judgment of 29 September 2025) reiterates its doctrine regarding the principle of full regularisation (“regularización íntegra”) in VAT matters. The Supreme Court states that Tax Authorities must...more
Ultra Health operates licensed medical cannabis dispensaries and cultivation facilities in New Mexico. On Oct. 2, 2024, the Internal Revenue Service (IRS) issued Ultra Health a notice of deficiency for its tax years ending...more
This Freeman Law Insights blog provides general legal information (not legal advice) about Texas sales tax on horse boarding and related sales and options that a collector of sales tax may take to rectify the collection of...more
As the shutdown of the federal government hits the one-week mark, many in the alcohol industry are asking “does this impact my company?” The alcohol industry is not only regulated by state or local agencies. The federal...more
Effective October 1, 2025, the state of Florida no longer requires sales tax or discretionary sales surtax on commercial lease payments. This landmark change eliminates a longstanding tax burden and can help streamline...more
In BellSouth Telecommunications, LLC et al. v. Ala. DOR, Ala. Tax Tribunal, Dkt. No. S. 22-829-LP (Sep. 23, 2025), the Alabama Tax Tribunal upheld the Department of Revenue’s denial of a sales tax refund sought by a...more