News & Analysis as of

State and Local Government Corporate Taxes

Cozen O'Connor

Illinois Insights: An update from Cozen O'Connor (7/30)

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Pritzker says Illinois working to soften impact of SNAP cuts imposed by Trump - “Gov. JB Pritzker spoke at an East St. Louis food shelter on Tuesday to talk about his administration’s plans to alleviate the impact spending...more

Kilpatrick

5 Key Takeaways: Business and Nonbusiness Income

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Kilpatrick’s Jordan Goodman recently co-presented the session “Income Subject to Allocation” at the Institute for Professionals in Taxation’s “2025 State Income Tax School” in Atlanta. Jordan addressed the distinction between...more

Husch Blackwell LLP

Tax Credit Transfers May Have Unexpected State Tax Consequences

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One of the most celebrated features of the Inflation Reduction Act (“IRA”) is the ability to sell tax credits, including the Production Tax Credit (“PTC”) under Internal Revenue Code (“IRC”) § 45 and the Investment Tax Credit...more

Kilpatrick

4 Key Takeaways | A National State and Local Tax Update

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Kilpatrick’s David Hughes and Jordan Goodman gave a national SALT update at the high-profile AGN International “2025 Americas Regional Meeting” in Toronto on June 3....more

Eversheds Sutherland (US) LLP

Eversheds Sutherland SALT Scoreboard – Quarter 1, 2025

This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more

Blank Rome LLP

Deference Denied to the South Carolina Department of Revenue

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The South Carolina Court of Appeals determined that Duke Energy Corporation (“Duke”) was entitled to claim nearly $25 million in investment tax credits on its 1996 to 2014 South Carolina income tax returns, as the investment...more

Blank Rome LLP

Gains on Sales of Franchises Held Nonbusiness Income in Arkansas

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Consistent with the decisions in several other states interpreting the Uniform Division of Income for Tax Purposes Act’s (“UDIPTA”) definition of nonbusiness income, an Arkansas Circuit Court concluded that gains from the...more

DarrowEverett LLP

Massachusetts Court Decision Could Spark State Tax Crackdown Nationwide

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Founders and executives with equity compensation need to be prepared for state tax exposure, even in states where they do not live. In a landmark decision that reverberates beyond Massachusetts, the Massachusetts Appeals...more

Akerman LLP - SALT Insights

It’s None of My Business! Arkansas Court Rules on Business v. Non-Business Income Distinction

Income received by a multistate business is either “business income” or “non-business income.” Although this labeling appears innocuous, the distinction between these two categories of income matters greatly to taxpayers and...more

Sheppard Mullin Richter & Hampton LLP

Alright, Alright, A Write-Off: Matthew Mcconaughey’s Push for Texas Film Tax Incentives

Texas has long been a hub for film and television production, offering diverse landscapes, a rich cultural backdrop, and some real characters. Back in 2007 the state implemented the Texas Moving Image Industry Incentive...more

Mayer Brown

STF Establishes Non-Incidence of ISS on Commissioned Manufacturing Activities

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The Brazilian Supreme Court (STF) decided that the Tax on Services’ (ISS) non-levy on toll commissioned manufacturing activities, whenever these activities refer to the intermediary activities of a production cycle. The...more

Pillsbury Winthrop Shaw Pittman LLP

Taxmageddon: What to Expect under Trump 2.0 and a GOP-Led Congress

With the Trump administration and a Republican-controlled Congress now in office, significant changes to the U.S. economic landscape and tax policy are expected. Indeed, legislation to change tax policy and to implement...more

Smith Anderson

2025 DOR Request for Legislative Changes

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The Department of Revenue (the “Department”) recently released two documents containing its “substantive” and “clarifying” requests for legislative changes to North Carolina’s revenue laws. Most of the requests include...more

Brooks Pierce

Brooks Pierce Capital Dispatch: Consensus Revenue Forecast Released, Helene Work Continues

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The recent release of the Consensus General Fund Revenue Forecast is a sign that work on the new state budget has begun. Although some legislators were in Raleigh this week, no votes were taken given inclement weather....more

Pillsbury Winthrop Shaw Pittman LLP

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

Buckingham, Doolittle & Burroughs, LLC

Ohio Commercial Activity Tax: Gross receipts from dialysis services are sitused entirely to the location where the treatment is...

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

Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 4, 2024

This is the fourth edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more

Freeman Law

Marketplace Sellers and Marketplace Providers

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I recently posted a blog about Texas sales tax nexus in which I laid out the basic rules for determining whether a taxpayer has nexus with the State of Texas (and thus has a permit, collection, and/or reporting requirement...more

Foley Hoag LLP

Annual Report Filing Reminders for DE, MA and NY

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This is a reminder that annual report filings are due in March 2025 for corporations formed or registered in Delaware and Massachusetts. New York biennial statements are due the last day of the calendar month in which a...more

Eversheds Sutherland (US) LLP

California’s proposed market sourcing reg raises questions

The California Franchise Tax Board (FTB) has proposed amendments to its regulations that govern how sales of services and intangibles are sourced for income tax purposes. The changes to this income tax apportionment...more

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

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A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Blank Rome LLP

Supreme Court of Ohio Affirms Denial of Healthcare Service Provider’s Commercial Activity Tax Refund Claim

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The Supreme Court of Ohio upheld the denial of Total Renal Care, Inc.’s (“TRC”) refund claim of Ohio Commercial Activity Tax (“CAT”) that it paid on services that it performed outside of Ohio. Total Renal Care Inc. v. Harris,...more

Brownstein Hyatt Farber Schreck

Maryland Governor Releases 2026 Budget Proposal

Last week, on Jan. 15, Gov. Wes Moore introduced to the Maryland General Assembly his fiscal year 2026 budget package. This $67.3 billion proposal, aiming to close the state’s nearly $3 billion budget gap, places a strong...more

Vorys, Sater, Seymour and Pease LLP

Attracting Aerospace: The Risks of a Property Tax-Heavy State Tax Structure

When examining the tax structures of business-aggressive states, a common pattern emerges: reduced income and franchise taxes offset by steeper sales and property taxes. While this approach may work for some industries, it...more

Buckingham, Doolittle & Burroughs, LLC

Challenges Businesses Face with Ohio State and Local Taxes

From understanding how businesses are taxed to navigating changes in Ohio tax regulations, it’s important to be aware of potential tax hurdles and how to proactively avoid them. This article from Buckingham, Doolittle &...more

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