Assessing Wayfair’s impact on business and professional service providers
States have been showing a trend toward taxing an increasing number of services.
State & Local Tax
Individual election to be taxed at corporate rates
Until now, shareholders had rarely invoked the Sec. 962 election to be taxed at corporate rates, and, as a result, most states have provided no specific guidance on how to treat a Sec. 962 election for state income tax purposes.
Why states should adopt the MTC model for federal partnership audits
To promote nationwide consistency, the AICPA encourages states’ adoption of the MTC model statute that conforms to the new federal partnership audit regime.
Oregon corporate activity tax: A new taxing regime
This discussion explores a few considerations for taxpayers potentially subject to Oregon's CAT.
IRS proposes more regulations on payments in lieu of charitable deductions
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.
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.
Practical implications of the Wayfair decision
Businesses can follow this six-step analysis to make sure they cover their bases in complying with new remote-seller sales-and-use-tax responsibilities.
Amended California EITC: Fiscal impact and effects on taxpayers
This discussion summarizes both versions of the CalEITC and how the 2019 amendments affect the calculation and the credit’s desired effects.
Wayfair’s impact on not-for-profit purchases and revenues
Not-for-profits that sell goods or services may find themselves needing to register for sales tax accounts in other states to remain in compliance.
US MNCs facing implications of economic (vs. physical) nexus
This item summarizes the complexities of a digitalized economy for MNCs and considers the multifaceted implications to U.S. MNCs with respect to financial statements and tax reporting.
Trust income: The Supreme Court’s narrow opinion on state nexus
The U.S. Supreme Court recently addressed the circumstances in which a state may levy income tax on a trust that has only minimal connection to the state.
Unclaimed property audit fallacies and myths
Raising revenue is increasingly taking primacy over reuniting owners with their property in states’ enforcement of unclaimed property laws.
Analyzing the new Oregon corporate activity tax
The new Oregon corporate activity tax requires quarterly estimated tax payments beginning in April 2020.
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.
SALT deduction cap rules finalized, safe harbor proposed
Here are details on the new rules that deny a federal tax deduction to taxpayers who donate to a state charitable fund and receive a state or local tax credit in return.
Passthrough entity taxes: The next workaround trend?
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.
New York’s response to Wayfair: Storms on the horizon?
New York's Notice N-19-1 provides some guidance to remote sellers doing business in New York, but several uncertainties remain.
New federal interest expense limitation meets old state related-party disallowance
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.
