State & Local Tax

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.

Tax reform in the Garden State

This item summarizes some of the important changes impacting the New Jersey corporation business tax and when these changes took effect or will become effective.

The TCJA and state considerations for business

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.

Managing corporate state net operating losses

This article offers guidance on maximizing the use of corporate state NOLs, recording deferred tax assets and valuation allowances for them, and incorporating their value in the pricing of M&A transactions.

Newsletter Articles

TAX REFORM

Traps for the unwary: Tax Cuts and Jobs Act changes

By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. Here is a list of changes together with (perhaps) unexpected nuances.

DEDUCTIONS

Qualified business income deduction regs. and other guidance issued

The package includes final regulations, guidance on how to calculate W-2 wages, a safe-harbor rule for rental real estate businesses, and new proposed rules on the treatment of previously suspended losses.