4 Key Takeaways | NY Sales Tax on Cloud-Based Document Management Services
Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
In an opinion issued on May 15, 2025, the State of New York Tax Appeals Tribunal, the highest administrative forum for state tax appeals, upheld the application of the state’s income tax “convenience rule” imposing New York...more
During the 2025 legislative session, the Georgia General Assembly passed several notable tax related bills including further decreasing the income tax rate and extending the time period for taxpayers to protest and appeal the...more
You are probably aware that many employers are discarding the fully flexible, remote work policies that were forced upon them – as “nonessential” businesses – during the COVID-19 pandemic[i] and which they retained as an...more
In another challenge to New York’s so-called convenience of the employer rule (the “convenience rule”), an Administrative Law Judge (“ALJ”) recently issued a determination upholding application of the rule against a...more
In a pair of decisions, a New York State appellate court has annulled decisions of the New York State Tax Appeals Tribunal that reduced certain tax credits available to the individual shareholders of their S corporation....more
The New York State Tax Appeals Tribunal ("Tribunal") held that a New York resident was not entitled to a resident tax credit for tax she paid to Connecticut on her carried interest. Matter of Greenberg, DTA No. 829737 (N.Y.S....more
Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more
Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
The South Carolina Department of Revenue (“DOR”, “SCDOR”, the “Department”) recently issued SC Information Letter #20-22 in which it released a series of helpful “Information Guides” concerning updated and specific...more
A common question in many Ohio commercial activity tax (CAT) audits is whether federal tax treatment may be relied upon. Although the statute says it should (R.C. 5751.01(K)), the Tax Commissioner is often reluctant to accept...more
Welcome to the latest issue of New York Tax Insights. In this issue we cover: Decisions from both the Appellate Division and the NYS Tax Appeals Tribunal holding it was unconstitutional to apply the April 2009 QEZE...more
The Tenth District Ohio Court of Appeals recently applied a statutory amendment clarifying the oil & gas exemption for Ohio sales & use tax retroactively. Interestingly, while this appeal was pending at the Board of Tax...more
Moving To Florida? A few days ago, one of the daily tax services reported that the billionaire investor and businessman, Carl Icahn, was planning to move his home from New York City to Florida, presumably for tax reasons....more
TRIBUNAL AFFIRMS DECISION SOURCING “OTHER BUSINESS RECEIPTS” TO WHERE THE WORK WAS PERFORMED - After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new...more
The Tax Bill signed by Governor Tom Wolf on October 30, 2017 made several significant changes to Pennsylvania tax laws that are estimated to generate additional revenue for the Commonwealth. Notable changes under the new law...more
On December 17, the Council On State Taxation (COST) announced that Alabama’s grade in their “Best and Worst of State Tax Administration” scorecard on Tax Appeals and Procedural Requirements, otherwise known as the “Due...more