Tax Court Modifies Rushmore Method for Hotel Valuation. The Maryland Tax Court recently modified the traditional Rushmore income approach used to determine the fair market value (FMV) of the real estate component of a hotel....more
1/31/2024
/ Advertising ,
Comptroller ,
Deed of Trust ,
Digital Media ,
Fair Market Value ,
Hotels ,
Personal Property ,
Private Letter Rulings ,
Property Tax ,
Recordation ,
State Taxes ,
Tax Assessment ,
Tax Court
Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more
10/31/2023
/ Administrative Hearings ,
Corporate Restructuring ,
Franchise Tax Board ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Non-Residents ,
Pass-Through Entities ,
Residency Status ,
S-Corporation ,
Sale of Assets ,
State Taxes ,
Subsidiaries
Clients frequently ask whether a business entity needs to register to do business in a particular state with which the entity has begun to have some degree of ongoing contact. In responding we typically consider the state's...more
8/23/2023
/ Business Formation ,
Business Taxes ,
Corporate Governance ,
Doing Business ,
Due Process ,
Forum Shopping ,
Mallory v Norfolk Southern Railway Co ,
Personal Jurisdiction ,
Registration ,
SCOTUS ,
State Taxes
Every so often something new and different comes along in the world of state and local tax that does not fit within the existing conceptual frameworks and rules. For example, the delivery of digital books and other digital...more
7/27/2022
/ Bitcoin ,
Bitcoin Mining ,
Blockchain ,
Cryptocurrency ,
Digital Marketplace ,
Digital Media ,
Income Taxes ,
Local Taxes ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Property Tax ,
Sales Tax ,
State Taxes ,
Unclaimed Property
A California state appellate court recently upheld the trial court's decision in The 2009 Metropoulos Family Trust v. Franchise Tax Board that nonresident shareholders of an S corporation source gain on the S corporation's...more
6/7/2022
/ Apportionment ,
Asset Purchase Agreements ,
Business Income ,
Family Trusts ,
Franchise Tax Board ,
Goodwill ,
Income Taxes ,
Internal Revenue Code (IRC) ,
S-Corporation ,
Sale of Assets ,
Shareholders ,
State Taxes ,
Subsidiaries ,
Tax Liability
California has revised its existing SALT cap work-around to address and liberalize several of the significant limitations on the work-around that we discussed in our prior alert.
On February 9, Governor Gavin Newsom signed...more