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New Mexico Again Loses Unity of Foreign Income

The New Mexico Taxation & Revenue Department (“Department”) wrongly ignored the statutory exclusion for foreign corporations incorporated in foreign countries that do not engage in a trade or business in the United States...more

Alabama Loses Interest Addback Attack, Yet Again

Alabama’s Department of Revenue (“DOR”) struck out again when it attacked related party interest transactions. In Huhtamaki, Inc. v. Alabama DOR, Docket Nos. BIT 19-890-JP, BIT 19-1091-JP (Ala. Tax Tribunal 2024), the Alabama...more

New Jersey Still Wrestles with Unity, but Don’t Forget the Rules

As the New Jersey Division of Taxation changes leadership and issues guidance regarding legislative changes, including for unity, it is time to recall some fundamentals of unity and put the unity statute change in context....more

Multistate Businesses Subject to the New Jersey Gross Income Tax Beware of Apportionment Change

It has long been a trap for the unwary, or a helpful tip for those in the know, that multistate income from business that is reported on a New Jersey Gross Income Tax (“GIT”) return is apportioned differently from the way...more

Look at What the Tax Does and Raise Everything to Win!

The Washington State Superior Court, Douglas County, (“Superior Court”) recently relied on the Washington State Constitution to invalidate the new Washington Capital Gains Tax (“WACGT”). Quinn/Clayton v. Washington, Douglas...more

What’s Shaking: Blank Rome State + Local Tax Roundup - November 2021

Blank Rome’s nationally prominent State + Local Tax attorneys are thought leaders in the community as frequent guest speakers at various local and national conferences throughout the year. Our State + Local Tax attorneys...more

What’s Shaking: Blank Rome State + Local Tax Roundup

Blank Rome’s nationally prominent State + Local Tax attorneys are thought leaders in the community as frequent guest speakers at various local and national conferences throughout the year. Our State + Local Tax attorneys...more

New Jersey to Require Inclusion of Federal Schedule UTP with CBT Returns—A Bad Idea

The New Jersey Division of Taxation recently added federal Schedule UTP (Uncertain Tax Position) to the list of federal income tax forms and schedules that must be included as part of a full and complete New Jersey...more

New Jersey Announces CBT Voluntary Compliance Initiative for Companies Included in Combined Returns

The New Jersey Division of Taxation (“Division”) recently extended an invitation for voluntary compliance with limited look-back and penalty waiver to companies that were included in mandatory unitary combined returns and...more

New Jersey Appellate Court Finds Payroll Tax Unconstitutional

In a precedential decision, New Jersey’s intermediate appellate court ruled that a Jersey City ordinance imposing a payroll tax was unconstitutional. Mack-Cali Realty Corp. v. State, No. A-3097-18, 2021 N.J. Super. LEXIS 21...more

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