Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more
The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more
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
On December 21, the New Jersey Division of Taxation released Technical Bulletin TB-85, which addresses how the Division will expect taxpayers to calculate the amount of so-called global intangible low-taxed income (GILTI) and...more
12/26/2018
/ Apportionment ,
Business Taxes ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Estate Tax ,
Foreign Derived Intangible Income (FDII) ,
GDP ,
GILTI tax ,
Governor Murphy ,
Internal Revenue Code (IRC) ,
State and Local Government ,
State Tax Equalization Boards ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Revenues
The year 2018 has been a monumental one for the state and local tax community. If the sweeping changes to the US federal tax code made by the federal Tax Cuts and Jobs Act of 2017 (TCJA) and continued efforts by the states to...more
11/2/2018
/ Capital Gains ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
U.S. Treasury
On June 11, 2018, Senate Bill 8991 (the Bill) was introduced by New York Senate Majority Leader John Flanagan. The Bill would decouple from the federal treatment of Global Intangible Low-Taxed Income (GILTI). ...more
The New York Legislature passed its 2018-2019 Fiscal Year budget on March 30, 2018 (Budget), which is expected to be signed into law by Governor Cuomo. The starting point for determining New York taxable income is federal...more