On September 2, 2015, the New York State Department of Taxation and Finance released draft amendments to the Article 9-A corporate franchise tax regulations to address significant changes relating to statutory nexus under...more
The Indiana Department of Revenue recently concluded that a company that earned royalty income from licensing trademarks and trade names to two of its Indiana affiliates, and had no physical presence in the state, nonetheless...more
In This Issue:
Ringing in the New Year: Issues from 2013 That Will Likely Impact 2014; Upcoming Speaking Engagements; Defending Against Penalties; and Dueling “Doing Business” Interstate-Commerce Exemptions:...more
The New Jersey Tax Court issued a written amplification of its bench decision in Lorillard Licensing Company LLC’s appeal that the Division of Taxation may not apply dual nexus standards for Throwout purposes.
In...more
In This Issue:
“Occasional Sales” and Single Sales Factor Apportionment in California; Upcoming Speaking Engagements; State Taxation of Financial Institutions; Applying the True Object Test to Determine the Taxability...more
Introduction -
In a period of 18 months, three state courts have refused to extend economic nexus approaches to the facts before them, despite prior decisions in those states that corporations without physical presence...more
In response to numerous inquiries for copies of our Transcript of ruling and argument following our August 22, 2013 alert, of the New Jersey Tax Court’s bench ruling that the Division of Taxation may not apply dual nexus...more
Nexus — whether a corporation has a sufficient connection such that it may be taxed by a state — is one of the most important issues in state tax. Various legal theories have been asserted (and are being asserted) to justify...more
In This Issue:
Sales Tax Nexus Developments in California and Beyond: A Year in Review; Upcoming 2013 Speaking Engagements; Recent MoFo State + Local Taxpayer Victories; Exploring the Subject to Tax Exception to Addback...more