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Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 1, 2024

This is the first 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

Blank Rome LLP

New Jersey Tax Court Awards Company a Refund Based on Its Use of Market-Based Sourcing for Years Prior to New Jersey’s Adoption of...

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In an unpublished opinion, the New Jersey Tax Court held that a web-based business solutions company was entitled to use market-based sourcing to source its 2011 and 2012 receipts even though market-based sourcing was not...more

Eversheds Sutherland (US) LLP

Georgia’s 2024 legislative session: Sine Die tax legislation overview

The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more

Venable LLP

Maryland Tax Updates - January 2024

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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

Blank Rome LLP

Sales Tax & Bad Debts: Win at Indiana Tax Court Follows Federal

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Financed transactions can result in states asserting "heads I win, tails you lose" by taking the tax at the time of sale but not accepting pain when the installment sale is busted. When a sale of tangible personal property...more

Blank Rome LLP

A Lack of Transparency: Minnesota Edition

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Taxpayers and practitioners are often stymied by the lack of clarity or other information provided by state departments of revenue on tax issues. While the limited information can be understandable when a department does not...more

Blank Rome LLP

Minnesota Tax Court Addresses What Constitutes Solicitation under Public Law 86-272

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The challenges in establishing protection under Public Law 86-272 (“P.L. 86-272”) were on display in a recent decision of the Minnesota Tax Court. Uline, Inc. v. Commissioner of Revenue, Minn. Tax Court, No. 9435-R (June 23,...more

Pillsbury - SeeSalt Blog

Minnesota Tax Court Denies a Catalog and Internet-Based Distribution Company Public Law 86-272 Protection

The Minnesota Tax Court held a catalog and internet-based distribution company exceeded the protections of Public Law 86-272 (PL 86-272) by providing non-sales personnel with information about competitors’ products and sales...more

Rivkin Radler LLP

Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?

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Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more

Freeman Law

Texas Tax Roundup | April 2023: Pleas to the Jurisdiction, Retail and Wholesale Franchise Tax Rate, and More

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Howdy folks, and welcome back to another edition of the Texas Tax Roundup, where we gab about all things Texas tax and perhaps even some things Texas tax adjacent. As ole T.S. once put it, “April is the cruelest...more

Freeman Law

Texas Tax Roundup | January 2023

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Hiya, folks and welcome back to a whole new edition (in a whole new year) of the Texas Tax Roundup! January started the year off with a blast! Let’s see what happened!   Sales and Use Tax  Governmental Exemption...more

Bradley Arant Boult Cummings LLP

The Top 5 "Hottest" Alabama Tax Cases in the Past Year

We summarize here what we believe are the top 5 Alabama tax cases decided in the past year that would interest our CPA readers.  Not surprisingly, almost all are Alabama Tax Tribunal rulings, so in those instances we deleted...more

Freeman Law

Texas Tax Roundup | December 2022: Sweepstakes, Medical Records, and More!

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December was a bit of a slow month on the Texas tax front. Hopefully everyone was out of their respective offices and enjoying the holidays/resting up for the upcoming legislative session. Still, we got an interesting opinion...more

Akerman LLP - SALT Insights

Texas Supreme Court Rejects Texas Comptroller’s “Receipt-Producing, End-Product” Act Test for Sourcing Receipts from Services

On March 25, the Texas Supreme Court issued a highly-anticipated decision concerning the proper test to source receipts from services for purposes of Texas franchise tax. By statute, receipts from a “service performed in this...more

Blank Rome LLP

New Jersey Tax Court Rules that the Division Cannot Offset a Taxpayer’s Refund against a Liability from a Closed Tax Year

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On January 19, 2022, the New Jersey Tax Court issued a decision denying the Division of Taxation’s attempt to take away a refund due to a taxpayer and apply it against a purported liability from a tax period for which the...more

Lewis Roca

2021 Arizona Tax Updates

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TRANSACTION PRIVILEGE TAX UPDATES LEGISLATION - Senate Bill 1110, Chapter 443. Tribal Exemptions. This bill codified the following exemptions applicable to Indian tribes and tribal members at A.R.S. § 42-5121 et seq.: (1)...more

Freeman Law

[Webinar] Legal and Tax Update - July 28th, 2:00 pm CT

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Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

BakerHostetler

[Podcast] Did Texas Make It Easier to Get Tax Cases into Court?

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The Texas Legislature has passed HB 2080 which tempers Texas' "pay to play" system for judicial review of tax cases and SB 903, which allows taxpayers to skip an administrative hearing on refund cases. Matt Hunsaker, a...more

Foster Garvey PC

What House Bill 4212 and Chief Justice Order No. 20-027 Mean for Oregon Taxpayers

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During the first special session of 2020, the Oregon legislature passed House Bill 4212 (“HB 4212”). Governor Kate Brown (the “Governor”) signed HB 4212 into law on June 30, 2020. HB 4212 extends the time periods that...more

Eversheds Sutherland (US) LLP

What you need to know today about COVID-19 and California taxes

Not even state taxes are immune from the COVID-19 pandemic. Below is a quick checklist – as of the time of publication – of coronavirus-related items and concerns affecting California state taxes....more

Schwabe, Williamson & Wyatt PC

COVID-19: Taxing Authorities Make Moves to Address COVID-19

Federal, state, and local taxing authorities have been making moves to address COVID-19. Here is what we know: Federal Government - Earlier this month, Treasury Secretary Steven Mnuchin (“Treasury Secretary”) informed...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

Morrison & Foerster LLP

New Jersey Tax Court Rules That Intercompany Payments Are Not Taxes for Purposes of the State Tax Addback

The Tax Court of New Jersey released its state tax addback decision in Daimler Investments US Corporation v. Director, Division of Taxation on January 31, 2019. The Tax Court agreed with our assertion that amounts Daimler...more

Morrison & Foerster LLP

New Jersey Tax Court Upholds Taxpayer’s Three-Factor Apportionment Formula

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The Tax Court of New Jersey released a published decision in ADP Vehicle Registration, Inc. v. Director, Division of Taxation on December 11, 2018. The Tax Court’s precedential decision rejected New Jersey’s attempts to...more

Morrison & Foerster LLP

State + Local Tax Insights: Summer Issue 2018

Words Matter: Complying with State Tax Laws - Statutes mean what they say. As the late Justice Scalia once quipped, the proper role of the courts “is to apply the text, not to improve upon it.” However, revenue departments...more

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