News & Analysis as of

Tax Cuts and Jobs Act Income Taxes Apportionment

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

Kilpatrick on

Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Pillsbury - SeeSalt Blog

Reminder: “Gross” Does Not Mean “Net” – California OTA Holds All Repatriated Dividends Must Be Included in Sales Factor

In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator....more

Cadwalader, Wickersham & Taft LLP

Moore Bark Than Bite? Supreme Court Weighs In

Unless you have been living under a rock—as we tax lawyers are wont to do—you have probably been following Moore v. United States, which we last discussed.  On December 5, the tax community stepped into the spotlight...more

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

Rivkin Radler LLP on

Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

Miller Canfield

Will the Supreme Court Invalidate One or More Sections of the Tax Cuts and Jobs Act?

Miller Canfield on

A tax case pending in the United States Supreme Court, Moore v. United States, may cause a cataclysmic change in the federal income tax. The 16th Amendment to the United States Constitution empowers Congress to impose “taxes...more

Skadden, Arps, Slate, Meagher & Flom LLP

State and Local Tax Considerations in Light of COVID-19

The first order of business for many state tax authorities in response to COVID-19 was deciding whether to extend their respective income tax filing and payment deadlines for the 2019 tax year, either automatically by...more

Smith Anderson

2019 North Carolina Tax Legislation

Smith Anderson on

This Alert summarizes the more significant tax provisions enacted by the North Carolina General Assembly in 2019.  The most important tax changes were originally included in House Bill 966, the 2019 Appropriations Act (the...more

Eversheds Sutherland (US) LLP

New York instructs taxpayers on GILTI apportionment

The New York State Department of Taxation and Finance released guidance in the form of tax return instructions addressing how it will account for global intangible low-taxed income (referred to as GILTI) for apportionment...more

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