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New Jersey Tax Court Approves Use of Market-Based Sourcing for Years Prior to Legislature’s Adoption of Market-Based Sourcing

The New Jersey Tax Court held that a taxpayer was entitled to a refund of corporation business tax (CBT) for tax years 2011 and 2012 after determining the taxpayer correctly used a market-based sourcing methodology to source...more

Try, Try Again—New York’s Convenience of the Employer Rule Sources Nonresident Wages to New York Even During the Pandemic

A New York nonresident taxpayer, Edward Zelinsky, recently filed a notice of exception to a Division of Tax Appeals’ (DTA) determination that he must allocate all his wages to New York under the so-called “convenience of the...more

“No Sugarcoating: The California Office of Tax Appeals Limits the California FTB’s Application of Legal Ruling 2006-01”

In the Appeal of Southern Minnesota Beet Sugar Cooperative (2023-OTA-342P) (Beet Sugar), the California Office of Tax Appeals (OTA) issued a precedential opinion holding the California Franchise Tax Board (FTB) is not...more

Pennsylvania Legislation Provides Updates to Corporate Income Tax Law

The Pennsylvania Governor signed H.B. 1342 to enact changes to the state’s corporate income tax.  The legislation modifies the corporate income tax in three ways: (1) adopts a bright-line economic nexus standard; (2) adopts...more

New Tax Legislation Shifts Consolidated Return Landscape in Georgia

For tax years beginning on or after January 1, 2023, affiliated groups may elect to file a consolidated Georgia income tax return without having to seek the permission of the Georgia Department of Revenue. The principal...more

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