News & Analysis as of

Tax Liability State Taxes

Blank Rome LLP

New York ALJ Finds Convenience of Employer Rule Applicable to Nonresident but Provides a Roadmap for How a Taxpayer May Prove the...

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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

Blank Rome LLP

NYC Judge Applies Step Transaction Doctrine but Cancels Real Property Transfer Tax Assessment

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A recent New York City (“NYC”) determination limited the impact of the step transaction doctrine under the New York City real property transfer tax (“RPTT”). An Administrative Law Judge (“ALJ”) held that the collapsing of a...more

Bowditch & Dewey

Massachusetts Tax Amnesty Announced

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The Massachusetts Department of Revenue (DOR) recently announced a tax amnesty program for non-filers and those with outstanding tax liabilities. From November 1 to December 30, 2024, most penalties for eligible taxpayers who...more

Rivkin Radler LLP

New York Tax Continues to Inconvenience Nonresidents Working Remotely

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Last Friday, New York’s Governor Hochul delivered the following remarks at the annual meeting of the Business Council of New York State:“Someone asked me today, are we going to raise income taxes? I said, ‘I’m not raising...more

Miles & Stockbridge P.C.

Massachusetts Announces Limited Tax Amnesty

The Commonwealth of Massachusetts will offer a limited tax amnesty for certain “eligible taxpayers” from Nov. 1 through Dec. 30. “Eligible taxpayers” can forward and bring their tax liabilities up to date and receive a...more

Blank Rome LLP

Maryland’s Digital Advertising Tax Survives First Amendment Challenge (For Now)

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On July 3, 2024, the U.S. District Court for the District of Maryland dismissed a First Amendment challenge to Maryland’s Digital Advertising Gross Revenues Tax (the “Tax”) holding that while a provision in the Tax scheme...more

Morgan Lewis

Upcoming Deadline to Dispute California Property Tax Valuation

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For California property owners that could potentially reduce their property taxes with a decline-in-value assessment appeal, the property tax assessment appeals for 2024 are due by either September 16 or December 2 depending...more

Kilpatrick

5 Key Takeaways - Council On State Taxation (COST) Regional State Tax Seminar

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Kilpatrick’s Samantha Breslow, Jordan Goodman, David Hughes, and Jeffrey Reed presented “Discussion of State Tax Cases, Issues & Policy Matters to Watch” and “Where’s Waldo? Sales Sourcing in Today’s SALT World” during the...more

Bowditch & Dewey

Olympic Medals and Income Tax

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The 2024 Paris Olympics are in full swing, and it is never too early for U.S. athletes to consult with their tax advisor. As was done in 2021, the United States Olympic & Paralympic Committee has pledged to award U.S....more

Blank Rome LLP

To Be or Not To Be A Unitary Business

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Oftentimes companies are on the defense in establishing that they are not operating a unitary business to avoid excessive taxation by a State. Yet, there are occasions when companies take the offense—and are successful. In...more

Farrell Fritz, P.C.

Understanding New York State's STAR Program

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New York State offers the School Tax Relief (STAR) program to provide a bit of property tax relief to eligible homeowners. ...more

Baker Donelson

SALT Select Developments - July 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Kilpatrick

Introduction to the Illinois Franchise Tax and its Importance to Your Company

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The Illinois Franchise Tax (the “Franchise Tax”) is an extremely complex tax that places unique burdens on corporations conducting business in Illinois. Based on our experience, many corporations incorrectly calculate their...more

Kilpatrick

Calculating Allocation Factor for Illinois Franchise Tax Purposes

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The importance of calculating your Franchise Tax Allocation Factor cannot be understated. Improper calculation of this factor can lead to over and underpayment of Franchise Tax, triggering penalties, interest accrual, and the...more

Kilpatrick

Commons Problems and Simple Solutions

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This series of articles is intended to provide a deep dive into the Illinois State Franchise Tax (the “Franchise Tax”) and should be read sequentially to be best understood. The first article covered the businesses and...more

Morgan Lewis

California Digital Advertising Tax Bill Progresses to Assembly Committee on Revenue and Taxation

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The Digital Advertising Services Tax Law passed the California Assembly Committee on Privacy and Consumer Protection with a 6-3 vote on April 23 and is now pending before the California Assembly Committee on Revenue and...more

Cadwalader, Wickersham & Taft LLP

Location, Location, Location: New York’s Apportionment Rules for Investment Managers

New York State recently issued final corporate franchise tax regulations for sourcing income (the “Regulations”), including specific sourcing rules for service fees paid by passive investment customers (“PICs”) to investment...more

Cadwalader, Wickersham & Taft LLP

Should I Stay or Should I Go? Hedge Funds: Crypto and State Tax

Hedge fund managers have a state tax gating issue when it comes to adding crypto to their assets under management. Generally, states such as New York, Connecticut and California encourage asset managers to locate in their...more

Blank Rome LLP

Understanding Residency and Domicile in Determining State Income Taxation

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State income taxes play a prominent role in overall tax planning for individuals. A change of residence/domicile from a higher-tax state to a lower- (or no-) tax state is often considered when contemplating retirement or the...more

Blank Rome LLP

New York ALJ Rejects Division of Taxation’s Attempt to Change Its Theory of Liability after the Hearing

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A New York State Administrative Law Judge (“ALJ”) recently rejected an attempt by the Division of Taxation (“Division”) to change its theory of liability after the record was closed, raising its new theory of liability for...more

Baker Donelson

Summaries Released of Select Informal Conference Decisions

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The Tennessee Department of Revenue (Department) recently posted certain selected informal conference summaries which provides taxpayers with insight into how the Hearing Office will address various issues arising under...more

Williams Mullen

[Event] Winter Tax Forum 2024 - January 31st, Richmond, VA

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Join Williams Mullen partners for our in-person Winter Tax Forum on Wednesday, January 31, 2024. Our speakers, Farhad Aghdami, Jenny Connors, Conrad Garcia and Beth Hungate-Noland will present on partnership aggregators and...more

Troutman Pepper

The Continuing Negative Impact of Federal and State Taxation on the Cannabis Industry; Where Do We Go from Here?

Troutman Pepper on

The cannabis industry has experienced significant growth over the past decade, with increasing numbers of states legalizing both medical and recreational use. Currently, cannabis is legal for adults in 24 states and the...more

Baker Donelson

SALT Select Developments - January 2024

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Bradley Arant Boult Cummings LLP

A cautionary tale: Challenges for firms in Wayfair compliance

Law firms periodically receive requests for advice from CPAs regarding a client’s need to come into compliance with the relatively new and sometimes confusing “economic nexus” or “Wayfair” rules for selling goods or providing...more

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