News & Analysis as of

Limited Liability Company (LLC) Tax Appeals

Vorys, Sater, Seymour and Pease LLP

The Evaluator - Winter 2025: Ohio Property Tax Updates

The Legislative Changes to HB 126 Introduced in 2024 Were Not Enacted Into Law - In 2024, there were two separate efforts by the Ohio legislature to amend House Bill 126 (HB 126) to address and clarify issues that have...more

Rivkin Radler LLP

Choice of Entity for a U.S. Business- Passthrough Status Matters Beyond the U.S. Border

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Decisions, Decisions - The owners of a closely held U.S. business will have to make many difficult decisions during the life of the business. Among the earliest of these is the so-called choice of business entity, the...more

Rivkin Radler LLP

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

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The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

McDermott Will & Emery

Buehler Doesn’t Get a Day Off from Double Taxation

McDermott Will & Emery on

The California Office of Tax Appeals (OTA) recently held that a California resident’s income tax paid to Massachusetts from the sale of his membership interest in a limited liability company (LLC) doing business in...more

Rivkin Radler LLP

Personal Liability for NY Sales Taxes –Sometimes, There’s No Denying It

Rivkin Radler LLP on

It wouldn’t be far-fetched to say that, as a species, we humans have a propensity – rooted in our instinctive tendency for self-preservation – toward denying anything we believe may cause us harm. It should come as no...more

Rivkin Radler LLP

Will New York Be Looking At Your Federal Tax Return? Probably

Rivkin Radler LLP on

State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more

Rivkin Radler LLP

The Rental of Art Between Related Parties: Applying the Resale Exclusion to the N.Y. Sales Tax

Rivkin Radler LLP on

“Yes” to Art, “No” to Tax- Private patronage of the arts. For centuries, artists, museums, and galleries have depended, in no small part, upon the largesse of wealthy families. Today, as in the past, many of these...more

Patton Sullivan Brodehl LLP

“Drop and Swap” — Tax-Friendly Handling of a Dissolving LLC’s Real Property

A common LLC problem: LLC members are ready to call it quits on the LLC and divide their interests in the LLC’s real property. Some members may want to sell, receive cash, and recognize gains for tax purposes. Other...more

Allen Matkins

California Office of Tax Appeals Upholds Taxpayer Friendly "Drop and Swap" Case

Allen Matkins on

On January 28, 2020, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request to rehear In the Matter of the Appeal of Sharon Mitchell (OTA Case No. 18011715). This decision may...more

Pillsbury - SeeSalt Blog

California OTA Rejects FTB’s 0.2 Percent Bright-Line Nexus Standard for Out-Of-State Minority Interest LLC Members

The California Office of Tax Appeals (OTA)—in a 3-0 pending precedential opinion granting the Appeal of Jali, LLC—has rejected the Franchise Tax Board’s (FTB) 0.2 percent ownership threshold as the new bright-line standard...more

Patton Sullivan Brodehl LLP

Will Using an LLC Mess Up a Property Tax Base Transfer Under California Law?

Under California’s Proposition 60, which became enacted in 1986 as Revenue and Taxation Code section 69.5, any “person” over the age of 55 years may transfer the base year value of his or her residential property to any...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 7

ALJ holds NYS Real Estate Transfer Tax Cannot Be Imposed on Sale of 45% Membership Interest in LLC - In an issue of first impression under the New York State real estate transfer tax, a New York State Administrative Law...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 7 - July 2015

In This Issue: - Important Changes at NYS and NYC Tax Agencies - Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions - NYC Tribunal...more

Pullman & Comley, LLC

Property Tax And Valuation Topics - Summer 2015

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The Environment and Property Taxes - It seems that many stakeholders are trying to deal with climate change. Connecticut’s hundreds of miles of coastline along the Long Island Sound include many low-lying areas...more

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