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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
As far back as I can remember, the end of August has always elicited a sense of dread comparable to what many schoolchildren, and a fair number of adults, experience every Sunday afternoon. In retrospect, I cannot say that...more
Both states and taxpayers have struggled with how to correctly source service receipts for apportionment purposes. The myriad of state sourcing provisions certainly do not add any clarity to the issue. Muddying the waters...more
The Oregon Legislature, in House Bill 3373, created the Office of the Taxpayer Advocate within the Oregon Department of Revenue. The new law became effective on September 25, 2021. According to the Oregon Department of...more
The Multistate Tax Commission recently issued a policy position on not disclosing which states nominated a taxpayer for a joint audit or why they were nominated. Matt Hunsaker discusses....more
The Louisiana Department of Revenue (the Department) issued Revenue Information Bulletin No. 21-029 (the Bulletin), inviting corporate income taxpayers to resolve intercompany transfer pricing issues via the Louisiana...more
The New Jersey Tax Court held that the Division of Taxation (“Taxation”) cannot assess tax in years open under the statute of limitations if the tax is attributable to the elimination of net operating loss (“NOL”)...more
According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
Throughout November, various Multistate Tax Commission committees held virtual annual meetings (due to COVID). In this episode, Matt Hunsaker runs down the highlights from each meeting, including technical corrections to...more
In our previous post, we explained the Ohio Department of Taxation proposed a regulation change to limit a taxpayer’s ability to make a retroactive consolidated filing election for Ohio Commercial Activity Tax purposes (CAT)....more
Many people are looking to move out of high tax jurisdictions - for a variety of tax and non-tax reasons. State tax officials audit residency changes with vigor. Betsy Smith joins Matt Hunsaker in the virtual studio to...more
Conforming- About sixty years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return...more
The South Carolina Department of Revenue (SCDOR or DOR) recently issued a draft of long-awaiting guidance overhauling DOR’s administrative practices concerning disputed tax audits, refunds, license revocations, and other...more
We invite you to join us for our annual “Year in Review” Tax in the City® Chicago. We will discuss current tax issues including: • Judicial deference and potential impact on TCJA audits • Taxation of the digitalized...more
The Ohio Department of Taxation (“The Department”) investigates and institutes various types of audits to explore potential non-compliance by businesses. Thus, Ohio businesses should be aware that this potential cost and...more
• President Donald Trump on Dec. 22, 2017, signed the Tax Cuts and Jobs Act, the first major overhaul of the U.S. tax system in over 30 years. • Although few of the enacted provisions are specific to Indian Country, several...more
The South Carolina Department of Revenue (SCDOR) administers the state’s tax laws. Like the IRS, SCDOR audits tax returns, but only certain returns subject to South Carolina tax, such as South Carolina income tax returns,...more