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Tax Liability SALT

Ankura

Tax Liability Insurance - M&A and Beyond

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During the diligence phase of a transaction, it is not uncommon for a buyer to identify potential tax liabilities that may be caused by a number of situations: uncertainty over a tax structure, an estimated fair market value...more

Baker Donelson

SALT Select Developments - July 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

Baker Donelson

SALT Select Developments - January 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

Freeman Law

Rentals Versus Services Under Texas Sales and Use Tax

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One of the thorniest issues in Texas sales and use tax is the distinction between the rental of tangible personal property (which is subject to tax) and the provision of a service (which is only taxable if the service is...more

Eversheds Sutherland (US) LLP

A dash of SALT on the deal: Key takeaways from TEI's 2023 M&A Seminar

State and local tax (SALT) issues may arise from mergers, acquisitions, or dispositions. Eversheds Sutherland Partner Todd Betor presented on Unique State Tax Issues at Tax Executives Institute’s 2023 Mergers & Acquisitions...more

Skadden, Arps, Slate, Meagher & Flom LLP

Taxpayers (and States) Take Notice: Invalidation of the Maryland Digital Advertising Tax Highlights the Importance of the Internet...

A Maryland state court invalidated the state’s first-in-the-nation tax on digital advertising (Maryland Digital Advertising Tax) earlier this week. Enacted in February 2021, the Maryland Digital Advertising Tax was...more

Akerman LLP - SALT Insights

What’s Next For Maryland’s Digital Advertising Tax?

Maryland’s controversial Digital Advertising Gross Revenues Tax (the “Digital Ad Tax”) recently shot back to the top of the headlines when Maryland Circuit Court Judge, Alison Asti, ruled from the bench that the tax is...more

Baker Donelson

SALT Select Developments - September 2022

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more

Akerman LLP - SALT Insights

Sirius XM Prevails in Texas Supreme Court on Sourcing of Receipts from Satellite Signal

In a recently issued taxpayer-favorable opinion, the Texas Supreme Court overturned the court of appeals’ decision holding that the state’s performance-based sourcing statute for service receipts essentially looks to customer...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

Dentons

Kentucky: Governor Beshear Halts Vehicle Property Tax Increase, Proposes Sales Tax Cut

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Kentucky Governor Andy Beshear issued an executive order on February 16, 2022 intended to stop an increase in vehicle property taxes for 2022. Used car values in Kentucky have risen approximately 40% since last year, from...more

Ward and Smith, P.A.

Rapid Fire Legal Update on Tax Provisions, E-Discovery, Lobbying Issues, and ADA Compliance

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We recently provided timely updates on new tax provisions, electronic discovery, lobbying issues, and ADA compliance during Ward and Smith's 2021 Virtual In-House Counsel Webinar. The following article highlights...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

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Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more

Polsinelli

The Proposed Build Back Better Act Moves Forward After the House Passes a Revised Version of the Bill

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Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more

Akerman LLP - SALT Insights

Louisiana Launches Unique State Transfer Pricing Initiative

Joining Indiana and North Carolina, Louisiana last week became the third state to offer an alternative to the burdensome and expensive process of enduring a state transfer pricing audit....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

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

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While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...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

Burr & Forman

South Carolina Joins Other States and Adopts Federal State and Local Tax Deduction Cap Workaround

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The State of South Carolina has now adopted legislation allowing “pass through” entities to elect each year to be taxed at the entity level on their active trade or business income instead of having their owners taxed at the...more

Morgan Lewis

State and Local Tax Responses to Covid-19 (UPDATED)

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Alabama - The Alabama Commissioner of Revenue has issued a series of orders. On March 18, 2020, the commissioner ordered that late payment penalties are waived for small retail businesses whose monthly retail sales during the...more

Freeman Law

[Webinar] Freeman Law Legal and Tax Update - March 30th, 1:00 pm CT

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Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. Business are still facing unprecedented challenges, and we are here to provide insights. During...more

Morgan Lewis

State and Local Tax Responses to Covid-19 (UPDATED)

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States and localities across the country are continuing to respond as quickly and effectively as possible to the coronavirus (COVID-19) outbreak. These responses include guidance for taxpayers on numerous topics, such as...more

Akerman LLP - SALT Insights

What Will Come of Maryland’s Unique and Controversial Digital Advertising Tax?

On February 12, 2021, overriding the Governor’s veto, Maryland enacted a first-of-its-kind tax “Digital Advertising Gross Revenues Tax” that has already sent shockwaves through the industry....more

Akerman LLP - SALT Insights

In Search of Revenue – Chicago Issues Bulletin on Economic Nexus For Streaming and Cloud Services

On January 21, 2021, the City of Chicago’s Department of Finance issued an informational bulletin clarifying its position regarding economic nexus for Chicago’s amusement tax as applied to streamed amusements and Chicago’s...more

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