Gross receipts from healthcare services delivered to dialysis patients were properly sourced to Ohio where the treatments were performed. Accordingly, the patients received the benefit of the dialysis services at the...more
The Ohio Board of Tax Appeals (“BTA”) held that vehicles sales made to Ohio buyers at a West Virginia dealership were not subject to Ohio Commercial Activity Tax (“CAT”). Straub-Nissan LLC, v. Harris, BTA Case No. 2022-422...more
On February 5, 2024, the Offices of the Controller and Treasurer & Tax Collector for the City and County of San Francisco published a report outlining tax reform recommendations in time to inform a potential ballot measure...more
Retailers and brand owners should be mindful of recent UK tax developments that impact taxation of gross receipts and taxation of digital activities. The new income tax charge on offshore receipts from intangible property...more
The Ohio Board of Tax Appeals recently allowed a taxpayer to retroactively elect to be taxed as a consolidated taxpayer for Ohio commercial activity tax, even after an audit had commenced. Nissan North America, Inc. v....more
On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”) regarding the base erosion and anti-abuse tax (generally referred to as the...more
On October 23, 2017, the Internal Revenue Service Office of Chief Counsel (Chief Counsel) concluded that certain merchant discount fees earned by a parent company in a consolidated group did not constitute domestic production...more
As I reported previously, Oregon Measure 97 was overwhelmingly defeated by voters in the state’s general election this past November. It certainly appeared that the voters spoke loudly and clearly on November 8, 2016, when...more
On June 29, President Obama signed into law the Trade Preferences Extension Act of 2015. Quietly embedded in Section 806 of this new law is a provision that doubled the cap on penalties, from $1.5 million to $3 million, for...more
James Susa analyzes the state tax statutory structures and major court decisions on bad debt deductions and concludes that in practice, the availability of such a deduction is limited in scope. Each state that imposes...more
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of recent legislation around the U.S....more
In This Issue: Commonwealth Court Denies Manufacturing Exclusion to Service Provider; PA Telecom Gross Receipts Litigation Finally Moving; Philadelphia Property Owners Take Notice! Reassessment Appeal Deadline...more
In a decision just issued as this newsletter was going to press, the Commonwealth Court has ruled that charges for private lines and for directory assistance are subject to Pennsylvania’s Gross Receipts Tax on...more