News & Analysis as of

Statutory Interpretation › State Taxes › State and Local Government

Cozen O'Connor

Exception to General Refund Limitations Period for PA Corporate Net Income Tax for Report of Change

Cozen O'Connor on

In an unusually taxpayer-friendly decision, a three judge panel of the Pennsylvania Commonwealth Court concluded that Section 406 of the Tax Reform Code of 1971 (the code), 72 P.S. § 7406, is an exception to the general...more

Blank Rome LLP

Internet Tax Freedom Act Preempts New York’s Imposition of Tax

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The New York State Tax Appeals Tribunal, affirming an Administrative Law Judge, held that the Internet Tax Freedom Act prohibits the Division of Taxation from subjecting to tax the receipts that Verizon New York, Inc....more

Vorys, Sater, Seymour and Pease LLP

Scope of Ohio Commercial Activity Tax Agency Exclusion Remains Unsettled Following Ohio Supreme Court’s Decision in Aramark Corp....

Vorys, Sater, Seymour and Pease LLP on

Aramark provided food service operations to various clients (e.g., hospitals, universities, corporations, sports arenas, etc.). The clients paid Aramark a management fee. In addition, the clients reimbursed Aramark for the...more

Vorys, Sater, Seymour and Pease LLP

Ohio Supreme Court Doubles Down on Applying a Plain and Ordinary Meaning to Sales Tax Exemptions

Vorys, Sater, Seymour and Pease LLP on

On August 13, 2025, the Ohio Supreme Court overturned the Ohio Board of Tax Appeals (BTA) and the Ohio Tax Commissioner in Claugus Fam. Farm, L.P. v. Harris, 2025-Ohio-2807, Slip Opinion No. 2025-Ohio-2807, thereby allowing...more

Blank Rome LLP

Deference Denied to the South Carolina Department of Revenue

Blank Rome LLP on

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

Blank Rome LLP on

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

Akerman LLP - SALT Insights

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

Akerman LLP - SALT Insights on

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

Pullman & Comley, LLC

Jurisdiction 101: Connecticut Supreme Court Hands Down Win For Taxpayers

Pullman & Comley, LLC on

In a victory for taxpayers across the nutmeg state, the Connecticut Supreme Court recently held in 7 Germantown Rd., LLC v. City of Danbury, No. 21024, 2025 WL 309848 (Conn. Jan. 28, 2025) (“Germantown”) that the appraisal...more

Stinson LLP

Are Airlines on the Hook for State and Local Taxes Addressing Homelessness?

Stinson LLP on

The tech explosion in West Coast cosmopolitan areas has exacerbated homelessness in the region, prompting state and local governments to enact or at least propose new taxes on large metropolitan businesses....more

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