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.
State & Local Tax
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.
States’ treatment of GILTI and FDII: The good, the bad, and the ugly
Review the various approaches states use to account for the GILTI and FDII regimes introduced by the TCJA.
Unintended consequences: Considerations for a marketplace seller
Marketplace sellers, especially smaller businesses with limited resources, may face unexpected liabilities and obligations.
IRS applies tax benefit rule to state and local tax refunds
The IRS issued guidance on the tax treatment of state and local refunds now that taxpayers are limited to a $10,000 deduction on their individual tax returns.
West Virginia cannot exempt state law enforcement pensions and tax federal ones
The U.S. Supreme Court held that West Virginia cannot provide a tax exemption to state law enforcement retirees while denying that exemption to federal law enforcement retirees who performed similar jobs.
Can a state tax a trust based on the beneficiary’s residency?
The U.S. Supreme Court heard oral arguments in a case that will decide whether states can tax trusts based solely on the fact that a trust beneficiary lives in the state.
Tax consequences for professional athletes in 2018
Proper advance planning is imperative to maximize the benefits of the TCJA provisions.
Tax treatment of state and local tax refunds clarified
The IRS issued guidance on the tax treatment of state and local refunds now that taxpayers are limited to a $10,000 deduction on their individual tax returns.
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.
State tax law cannot discriminate against federal pensioners, Supreme Court holds
The U.S. Supreme Court held that West Virginia cannot provide a tax exemption to state law enforcement retirees while denying that exemption to federal law enforcement retirees who performed similar jobs.
Alabama Scholastic case: Historic sales and use tax nexus issues with an eye toward Wayfair
A recent Alabama Court of Civil Appeals decision held that the business model used by a prominent classroom bookseller did not create use tax nexus in Alabama during a lengthy audit period at issue .
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.
