When the sale of an interest in a PTE is contemplated, planning for state sourcing and taxability of the gain should both be considered so the owners avoid a large — and sometimes unexpected — state income tax liability.
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State & Local Tax (SALT)
Update on states moving ahead with PTETs
States continue to move ahead with implementing new passthrough entity taxes as a workaround to the $10,000 cap on the federal deduction of state and local taxes.
Multistate businesses: What to do when state tax apportionment rules are unfair
Taxpayers may request an alternative method if they believe standard apportionment is not equitable in their situation.
South Dakota v. Wayfair — five years later
The expected and unexpected tax impacts of the landmark Supreme Court decision have increased the complexity of sales tax compliance for taxpayers.
Taxing marketplace facilitators: Sourcing issues
This items discusses how various types of revenue earned by marketplace facilitators may be sourced under state laws and regulations.
State tax considerations for financial institutions
This item identifies key state and local tax considerations financial institutions should timely review to be compliant and avoid traps for the unwary.
Personal income tax: The other-state tax credit
This item focuses on how states classify certain business taxes for these other-state tax credit purposes, using recent California developments to illustrate how states may analyze this issue.
Consequences of the MTC’s new interpretation of P.L. 86-272
Although the MTC’s revised interpretation will greatly restrict protections from state income taxes for some taxpayers, it could also present them with planning opportunities.
PTE deduction: Timing issues for accrual-method taxpayers
taxpayers and practitioners face uncertainty regarding the timing of the deduction provided for in Notice 2020-75.
Proven digital strategies for sales and use tax audits
Businesses must increasingly depend on big data, sampling, and artificial intelligence tools to anticipate and prepare for audits from cash-strapped state and local governments.
Significant state conformity issues for corporate taxpayers
This item reviews the most significant provisions of the TCJA and CARES Act affecting state corporate tax regimes and discusses state conformity issues that should be addressed by corporate taxpayers.
Continued challenges involving teleworking employees: The new normal
Complications of teleworking continue to arise, with each state making its own tax rules.
Cryptoasset issues in state and local taxation
This item highlights a few issues taxpayers should consider in income taxation, sales taxation, and unclaimed property/escheat reporting.
States’ reactions to MTC’s application of P.L. 86-272 to internet sales
The Multistate Tax Commission’s recent revision of its interpretation of P.L. 86-272 and corresponding state positions require remote sellers to reexamine their income tax nexus.
Sourcing Sec. 751(a) gain from nonresident’s sale of California partnership interest
Tax practitioners should be aware of the The California Franchise Tax Board’s two-step approach to transactions involving Sec. 751 gain.
Fulfillment by Amazon program does not create nexus with Pennsylvania
Merchandise held by Amazon in a Pennsylvania warehouse under a fulfillment program does not create Pennsylvania nexus for a nonresident retailer.
Federal implications of passthrough entity tax elections
Many questions remain with respect to the deductibility at the federal level of state income tax payments made by passthrough entities under new state tax regimes enacted to ameliorate the effect of the cap for individuals on the deduction of state and local taxes.
Questions to consider before electing into a PTE tax
Twenty-nine states have enacted a passthrough entity tax as a possible workaround to the federal state and local tax deduction cap.
State PTE elections: A big picture perspective
Practitioners may face a difficult analysis in helping their clients understand their possible PTE election opportunities.
Senate Finance airs post-Wayfair sales tax burdens
Small business owners describe scrambling to comply with varying sales tax compliance rules across a welter of jurisdictions.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
