Continued challenges involving teleworking employees: The new normal
Complications of teleworking continue to arise, with each state making its own tax rules.
State & Local Tax (SALT)
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.
Tennessee taxation of passthrough entities
An insufficient understanding of the rules can be dangerous to taxpayers when determining which entity has a filing responsibility in Tennessee.
Cryptoasset transactions: State corporate income tax implications
This item focuses on income classification and revenue-sourcing issues, with California law used to illustrate how states may address such issues.
State tax considerations around the sale of a partnership interest
This item discusses how owners selling partnership interests should address which states may attempt to tax the entire gain, how taxation of the gain may be divided among the states where the partnership does business, compliance considerations, and technical developments and trends that may affect the transaction.
SALT cap challenge is denied Supreme Court review
The $10,000 limitation on deducting state and local taxes stands after the Supreme Court refused to review a long-running lawsuit by New York and three other states.
Sales tax considerations for exempt organizations
Exempt organizations often dedicate resources to complying with federal tax laws but may not recognize the complexity of state and local sales and use taxes.
North Carolina’s recent tax reform through S.B. 105
Many of the changes provide a reduction of overall state taxes beginning in 2022 and forward.
Maryland breaks new ground in taxing digital realm
Maryland’s new sales tax regime expansively taxes digital products, and its digital advertising tax is the first of its kind.
Recent developments involving limitations to state NOL usage
taxable income with recognized losses. This item focuses on legislative developments in California, Illinois, and Kansas, as well as judicial decisions in Pennsylvania and New Jersey, that highlight imposed limitations on NOL usage.
A review of Multistate Tax Commission’s statement on how P.L. 86-272 applies to internet sales
The MTC approved a revision to its “Statement of Information Concerning Practices of the Multistate Tax Commission and Supporting States Under Public Law 86-272,” which added a section on activities conducted over the internet.
SALT payments before year end a priority for passthroughs
To be deductible at the entity level, payments by passthrough entities of state and local taxes should be made in the tax year of the liability, but state-specific elections may complicate that timing, tax advocates advise.
Decoding the Senate Finance Committee’s Build Back Better text
The Senate Finance Committee has released language for its portion of the reconciliation bill, which some lawmakers would like to pass before Christmas. Here’s what you need to know about the timeline and the bill, which includes several key tax provisions.
