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Tax Planning State and Local Government Corporate Taxes

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

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

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

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

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

McDermott Will & Schulte

“Voluntary” in Name Only? New Jersey Introduces Transfer Pricing Initiative

The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

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Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

Baker Donelson

SALT Select Developments - August 2021

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more

Gould + Ratner LLP

Pending Changes to Illinois Tax Laws Include SALT Workaround

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Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more

Shumaker, Loop & Kendrick, LLP

South Carolina Enacts SALT Cap Workaround

South Carolina recently joined the growing number of states to enact legislation that provides a state workaround to the $10,000 State and Local Tax (SALT) federal income tax deduction cap imposed on individual taxpayers by...more

Herbert Smith Freehills Kramer

New York State Budget Agreement Includes a Pass-Through Entity Tax as a SALT Workaround

On Wednesday, April 7, 2021, the New York Legislature reached an agreement with Governor Andrew Cuomo for the fiscal year 2021-2022 state budget. The agreed-upon budget package includes a number of revenue raisers ...more

Pierce Atwood LLP

COVID-19: Maine Income Tax Does Not Conform to FFCRA and the CARES Act

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Maine Revenue Services (MRS) has informed taxpayers that Maine does not conform to the federal tax changes enacted in the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security...more

Morgan Lewis

NJ Enacts Elective Pass-Through Business Tax to Limit Federal Cap Impact on SALT Deduction

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New Jersey recently enacted the “Pass-Through Business Alternative Income Tax Act,” which allows pass-through businesses with at least one member liable for the New Jersey gross income tax to make an election to pay income...more

Schwabe, Williamson & Wyatt PC

The DOR Issues Second Round of Temporary CAT Rules

Consistent with its plan announced late last year, this week the Oregon Department of Revenue (“DOR”) issued its second round of temporary administrative rules. This round of temporary rules was essentially a compilation of...more

McDermott Will & Schulte

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Ballard Spahr LLP

Pennsylvania Adopts Economic Nexus Standard for Corporate Net Income Tax

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In Corporation Tax Bulletin 2019-04, the Pennsylvania Department of Revenue (the Department) announced that, effective for tax years beginning on or after January 1, 2020, a corporate taxpayer with $500,000 or more of direct...more

Seyfarth Shaw LLP

New Illinois Law Eliminates Franchise Tax, Offers Tax Amnesty

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Illinois recently enacted legislation that offers significant benefits to delinquent taxpayers and corporations doing business in Illinois. The new legislation phases out the Illinois franchise tax over a four year period...more

Ballard Spahr LLP

Pennsylvania 2019 Tax Bill Adds Opportunity Zone Conformity for Personal Income Tax, Adopts New Sales Tax Provisions, and Amends...

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Act 13 of 2019 (Act 13), signed by Governor Wolf on June 28, 2019, made several changes to Pennsylvania tax laws, including the following significant changes. ...more

Foster Garvey PC

Oregon’s New Corporate Activity Tax

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We are taking a break from our multi-post coverage of Opportunity Zones to address a recent, significant piece of Oregon tax legislation. On May 16, 2019, Governor Kate Brown signed into law legislation imposing a new...more

Ballard Spahr LLP

Pennsylvania Allows Federal Depreciation for Corporate Net Income Tax (But Not Bonus Depreciation)

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Pennsylvania Governor Tom Wolf signed Act 72 of 2018 into law last week. Act 72 will allow Pennsylvania corporate net income tax (CNIT) taxpayers to use the federal Modified Accelerated Cost Recovery System (MACRS), but not...more

Pullman & Comley, LLC

Are Connecticut Income Taxes Now Tax Deductible For The Owners Of Pass-Through Entities?

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June 5, 2018 The Tax Cuts and Jobs Act, which was passed by Congress last year, imposed a $10,000 limit on state and local tax (“SALT”) deductions. ...more

Foodman CPAs & Advisors

Taxes in Florida

The Sunshine State is one of the lowest tax burden states in the US. Florida has no state individual income tax. At the state level, there is NO tax on social security benefits, retirement income, IRAs, 401(k) accounts,...more

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