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Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 2, 2024

This is the second 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

Baker Donelson

SALT Select Developments - April 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

Eversheds Sutherland (US) LLP

New York adopts final business corporation franchise tax regulations

On December 27, 2023, the New York State Department of Taxation and Finance (Department) officially adopted the business corporation franchise tax regulations it submitted to the State Register on August 9, 2023 – marking the...more

Freeman Law

Texas Tax Roundup | March 2023: Flowback, Welding, Local Taxes, and More!

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Franchise Tax - Apportionment - 34 Tex. Admin. Code § 3.591 (Margin: Apportionment)—The Comptroller adopted his amendments outlined in our previous post to implement the Texas Supreme Court’s opinion in Sirius XM...more

Bradley Arant Boult Cummings LLP

With IRS Partnership Audits Ramping Up, Will More States Enact the MTC Model Statute?

Landmark changes in the federal income tax treatment of partnerships (including multi-member LLCs) became effective in 2018 for many more partnerships than first anticipated. As a result of the Bipartisan Budget Act of 2015,...more

Blank Rome LLP

A Fee or a Tax? Beware of Localities Going Too Far

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On May 20, 2022, the Texas Supreme Court held that a locality lacked authority under Texas law to impose a licensing fee on a construction trash-hauling company that was calculated as a percentage of the company’s revenue....more

Freeman Law

Texas Tax Roundup | April 2022

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Hiya folks, and welcome back to another gripping installment of the Texas Tax Roundup. So, let’s ditch the small talk and get started! ...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

McDermott Will & Emery

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

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Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more

Sheppard Mullin Richter & Hampton LLP

California Passes “Workaround” To Federal Limit on State Tax Deduction For Certain Owners of Pass-Through Entities

On July 16, 2021, Governor Newsom signed California Assembly Bill 150 into law, allowing certain owners of passthrough entities to find a way around the current $10,000 federal cap on state and local tax (SALT) deductions for...more

BakerHostetler

[Podcast] NJ Nexus Initiative & Seattle Payroll Tax Update

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New Jersey is coming after taxpayers for years before 2019 based on information on combined group reports. From June 15 to October 15, 2021, the state will be offering certain benefits to taxpayers who come forward for years...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

Freeman Law

SALT Alert Texas Margin Tax Update Paycheck Protection Program (PPP) Loans

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On May 5, 2021, the Texas Governor signed into law House Bill 1195, which excludes federal PPP loans forgiveness as revenue for Texas Margin Tax (the “Margin Tax”). In response to the COVID-19 pandemic, the U.S. Congress...more

BakerHostetler

The Other Elections: State & Local Tax Ballot Results

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Everyone has been fixated on the presidential and congressional elections. But this election was chock full of state and local tax ballot measures. Some passed, some didn't - Matt Hunsaker breaks down the results in Arizona,...more

BakerHostetler

State Tax in Transactions: Apportionment & Combination Implications (Part III)

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In part 3 of our journey through SALT issues in M&A transactions, Matt Hunsaker highlights a few apportionment, unitary combination, and NOL usage implications that should be on your radar whenever you are involved in a...more

BakerHostetler

State Tax in Transactions - Expanding Nexus Footprint (Part II)

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M&A transactions can have big implications for your company's nexus footprint. In part two of the series on M&A transactions, Matt Hunsaker breaks down nexus issues that should be on your radar if your company is engaging in...more

Kilpatrick

5 TAKEAWAYS: New York Tax Litigation Update

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On August 19th, Kilpatrick Townsend State and Local Tax Partner Jeff Reed presented on a panel entitled New York Tax Litigation Update during a HalfMoon webinar. The panel discussed reported New York tax decisions from 2019...more

Bowditch & Dewey

Tax Incentives for Manufacturing Corporations

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In these challenging times, businesses might seek to evaluate whether certain local tax incentives offered by the Commonwealth of Massachusetts are available to them. “Manufacturing Corporations,” for example, receive a...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

Foster Garvey PC

The Old Wives' Tale, Curiosity Kills the CAT, Doesn’t Seem to Apply to Oregon’s New CAT

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On January 6, I presented a new White Paper, The Oregon Corporate Activity Tax – You Can Run and You Can Hide, but This New Tax Is Effective January 1, 2020, at the Oregon Society of Certified Public Accountants Annual State...more

McDermott Will & Emery

[Event] West Coast Tax Forum: California & Beyond: The Impact Of State, Federal And International Tax Developments On Golden State...

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Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges. Join members...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 8

Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..The New York State Department of Taxation and Finance’s release of revisions to its draft business corporate franchise tax regulations for...more

Ballard Spahr LLP

IRS Finalizes Regulations Disallowing Workarounds for State and Local Taxes

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The IRS recently published Final Regulations and Notice 2019-12 largely blocking state efforts to circumvent limitations on deductions for state and local taxes. (See our alert on the Proposed Regulations, issued in August...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

Morrison & Foerster LLP

NJ Tax Court Orders Full Unreasonable Exception to Royalty Addback

The New Jersey Tax Court held yesterday, February 27, 2019, in a precedential published opinion that a royalty payor was not required to add back any portion of the royalties that it paid to a related licensor under the...more

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