Tax Computation

A ruling by New York City’s Department of Finance indicates that businesses engaged in agreements to share office space may incur the city’s commercial rent tax.

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.

Tax practitioners should be aware of the The California Franchise Tax Board’s two-step approach to transactions involving Sec. 751 gain.

This item focuses on income classification and revenue-sourcing issues, with California law used to illustrate how states may address such issues.

This item examines the complex approaches used by Colorado, Maryland, and Oregon to adopt the
IRC on a rolling basis.

The TCJA’s interest expense deduction limitation
rules in amended Sec. 163(j) create significant challenges and uncertainty for taxpayers at the state level.

Plans adopted by some states sidestep the new federal Sec. 164(b)(6) limitation, which may not apply to income taxes imposed on a PTE.

The interplay between Sec. 163(j) and state expense disallowance leaves taxpayers in a position of having to make important decisions in a vacuum
of guidance.

Post-TCJA, practitioners and taxpayers should be aware of potential state conformity issues in areas
including interest expense deductions, qualified business income, net operating losses, and alternative minimum taxes.