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Recent nonstatutory state reactions to Wayfair

Several states have begun extending the economic nexus standard approved in Wayfair beyond sales tax, adopting economic nexus provisions for
corporate income taxes.

Guidance issued on payments to charitable organizations

The IRS issued additional rules on the treatment of deductions for charitable contributions in lieu of state and local taxes, an area in which it has already issued final regulations and other guidance.

M&A considerations in light of Wayfair

Buyers and sellers must now consider how Wayfair affects M&A tax due-diligence efforts, purchase agreement indemnities, and navigating remediation
plans between the parties around prior-period exposures.

Supreme Court holds North Carolina cannot tax trust

The U.S. Supreme Court issued a unanimous decision holding that North Carolina’s attempt to tax a trust based solely on the residence of a beneficiary violates the Due Process Clause of the 14th Amendment.