News & Analysis as of

Tax Tribunal

Jackson Lewis P.C.

New York Expands Rationale For State Income Tax “Convenience Rule”

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The November 30, 2023, opinion of a New York administrative law judge in In the Matter of the Petition of Edward A. and Doris Zelinsky upholds the state’s so-called income tax “convenience rule” with an expanded legal...more

Cadwalader, Wickersham & Taft LLP

“Ephemeral” Payments and Beneficial Entitlement

Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.  The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more

Eversheds Sutherland (US) LLP

Georgia’s 2024 legislative session: Sine Die tax legislation overview

The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more

Nelson Mullins Riley & Scarborough LLP

Gold Dome Report - Legislative Day 36 - March 2024

The General Assembly reconvened for Legislative Day 36 on Monday with lawmakers and lobbyists hoping to keep a little luck of the Irish going into the penultimate week of the legislative session. With only four legislative...more

Pillsbury - SeeSalt Blog

New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operating Location

The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the...more

Warner Norcross + Judd

This is Not a Tax Bill … Yet

If you own property in Michigan, then you just received (or will soon receive) a Notice of Assessment, Taxable Valuation and Property Classification from your local city or township. The phrase “THIS IS NOT A TAX BILL” is...more

Blank Rome LLP

Michigan Tax Tribunal Holds That Parent Properly Excluded its Wholly Owned Subsidiary from its Unitary Business Group Return

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Challenging a state corporate tax determination of a unitary business relationship between related corporations can be difficult. However, a recent decision of the Michigan Tax Tribunal shows that with good facts a business...more

Dechert LLP

Upper Tribunal Affirms FTT Bluecrest Decision on LLP Salaried Member Rules

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Asset managers established as LLPs will welcome the Upper Tribunal’s recent decision to uphold the decision of the First Tier Tax Tribunal (“FTT”) on the application of the salaried member rules in Bluecrest...more

McDermott Will & Emery

New York Budget Legislation Contains Significant Tax Provisions

New York Governor Kathy Hochul and the New York State Legislature have reached an agreement on the state’s fiscal year 2024 budget legislation. Most surprisingly, the legislation grants the New York State Department of...more

Baker Donelson

Spotlight on Alabama: Recent Tax Tribunal Decision Should Be of Interest to Employers Using Remote Workers

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A recent Tax Tribunal decision, Mark E. Bollinger v. State of Alabama Department of Revenue, Inc. 22-390-LP, should be of interest to Alabama employers using remote workers. In this case, Mark Bollinger worked for a large...more

Eversheds Sutherland (US) LLP

Proposed Georgia legislation attempts to deny Jobs Tax Credits earned in prior years

In 2021, the Georgia Tax Tribunal ruled that a non-profit hospital was entitled to use Quality Jobs Tax Credits (QJTC) against its unrelated business income tax and its payroll withholding tax. Floyd Healthcare Mgmt., Inc. v....more

Cadwalader, Wickersham & Taft LLP

Brakes Applied to a Speedy Reorganisation

The Upper tax tribunal (“Upper Tribunal”) has confirmed the decision of the First-tier tax tribunal (“FTT”), delivered in 2021, in the case of Kwik-Fit Group Limited and others v HMRC. This decision of the Upper Tribunal...more

Bradley Arant Boult Cummings LLP

New Tax Tribunal Ruling on Change-of-Residency Challenges

There seems to be an increased number of so-called “residency audits” being conducted by the Alabama Department of Revenue (ALDOR), as well as by other state tax authorities. These audits often result from the taxpayer filing...more

Bradley Arant Boult Cummings LLP

The Top 5 "Hottest" Alabama Tax Cases in the Past Year

We summarize here what we believe are the top 5 Alabama tax cases decided in the past year that would interest our CPA readers.  Not surprisingly, almost all are Alabama Tax Tribunal rulings, so in those instances we deleted...more

Rivkin Radler LLP

Push-Back On New York’s Mission to Tax Non-New Yorkers?

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Last week, Governor Murphy of New Jersey staked out a position on New York City’s congestion pricing proposal, stating that it “can’t be ‘on the backs of New Jersey commuters.’” “Whether it’s how we’re taxed by our...more

Blank Rome LLP

Interest Payment Not Required to Be Added Back as Alabama’s Subject-To-Tax Exception Applied

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On July 28, 2022, the Alabama Tax Tribunal held that a corporation is not required to add back interest paid to a related entity as the recipient was subject to tax on that income in Ireland. This was so even though the...more

BCLP

An update on relying on oral evidence from abroad in the UK Tax Tribunal

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In this blog, we consider the First-tier Tribunal (Tax Chamber)’s recent update to its guidance for parties wishing to rely on evidence given by a witness from outside the UK. The First-tier Tribunal (Tax Chamber) (the...more

Rivkin Radler LLP

New York to Taxpayer: “Forget What the Feds Said, You’re a ‘Responsible Person"

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Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more

Rivkin Radler LLP

Statutory Residence in New York: Time to Rethink the “Permanent Place of Abode” Test?

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Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more

Eversheds Sutherland (US) LLP

Georgia’s 2022 legislative session ends with significant tax legislation

During the 2022 legislative session, the Georgia General Assembly passed significant tax legislation, including authorizing affiliated groups to file consolidated corporate income tax returns without prior approval from the...more

Rivkin Radler LLP

The Rental of Art Between Related Parties: Applying the Resale Exclusion to the N.Y. Sales Tax

Rivkin Radler LLP on

“Yes” to Art, “No” to Tax- Private patronage of the arts. For centuries, artists, museums, and galleries have depended, in no small part, upon the largesse of wealthy families. Today, as in the past, many of these...more

Blank Rome LLP

Tax Appeals Tribunal Upholds Imposition of New York Sales Tax on IT Security Services

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The New York State sales tax on “protective and detective services” has been given an expansive reading by the New York State Tax Appeals Tribunal in a decision involving information technology (“IT”) security services. In In...more

Blank Rome LLP

Service Excluded from New York Sales Tax Since It Was Not Furnished to Others

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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

Pillsbury - SeeSalt Blog

Contractual Delivery Terms Control Application of Alabama’s Wholesale Oil License Fee

The Alabama Tax Tribunal held the taxpayers’ wholesale sales of fuel that entered and exited the state via the Colonial Pipeline were subject to the state’s wholesale oil license fee.  The sales in question were made to...more

Cadwalader, Wickersham & Taft LLP

Nonresident Corporate Partner Subject to NYC Tax on Sale of Partnership Interest

In Matter of Goldman Sachs Petershill Fund Offshore Holdings (Delaware) Corp., the New York City Tax Tribunal held that an upper-tier partnership’s passive corporate partner was subject to the New York City General...more

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