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California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment formula for financial institutions, aiming to increase tax revenue starting in tax year 2025. Update: On May 14, 2025, Governor Newsom released the May...more

California Governor Releases 2025 Budget Proposal to Move Banks and Financial Corporations to Single-Sales-Factor Apportionment

The proposal includes a shift to a single-sales-factor apportionment for financial institutions, aiming to increase tax revenue starting in tax year 2025....more

Arizona Court Shines (Sun)Light on Property Tax Treatment of ITCs

The Arizona Court of Appeals held that an investment tax credit (ITC) deferred as a tax asset has “value” and therefore is properly excluded from the taxable original cost of renewable energy equipment for Arizona property...more

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

South Carolina Legislature Forces New Standards for Forced Combination on Revenue Department

Under a new bill signed into law on March 11, 2024, the South Carolina Department of Revenue will have to satisfy additional standards before it may force affiliated corporate taxpayers to file a unitary combined return. ...more

A Hat Tip to the Manufacturing, R&D and Electric Power Industries: California Bill Would Provide Income Tax Credits for Sales and...

California’s Existing Partial Exemption for Statewide Sales and Use Tax Paid on Qualified Tangible Personal PropertyRTC section 6377.1 exempts from certain state sales and use taxes the sale of, and the storage, use or other...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

Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity

A Delaware state court struck down as unconstitutional a longstanding policy of the state’s taxing authority limiting NOL deductions of corporate taxpayers who file federal consolidated income tax returns. The Delaware...more

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