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.
Tax Computation
State PTE elections: A big picture perspective
Practitioners may face a difficult analysis in helping their clients understand their possible PTE election opportunities.
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.
Illinois PTE tax would provide SALT cap workaround
This item discusses Illinois Legislature's S.B. 2531, which includes a PTE tax that allows a workaround to the federal $10,000 limitation for state and local tax deductions.
Business property taxes: COVID-19’s effect on valuation
The COVID-19-related downturn and its impact on commercial property values offers an opportunity to claim favorable valuations on returns as they are filed or to challenge valuations from state taxing authorities.
Would you like SALT with that trust?
The total tax owed by a trust can be significantly affected by the location of grantors, beneficiaries, trustees, and even trust assets.
Difficulties of applying IRC rolling conformity in some states
This item examines the complex approaches used by Colorado, Maryland, and Oregon to adopt the IRC on a rolling basis.
COVID-19’s impact on withholding, unemployment insurance, and nexus
COVID-19 has added to employers' compliance requirements.
State implications of Sec. 163(j) under TCJA and CARES Act
States’ approaches to TCJA and CARES Act conformity will be driven by budget estimates and whether they can follow the reduction to the federal taxable income base while still balancing their budgets.
State considerations of Sec. 163(j) carryforwards
The TCJA's interest expense deduction limitation rules in amended Sec. 163(j) create significant challenges and uncertainty for taxpayers at the state level.
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.
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.
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.
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.
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.
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.
Proposed rules aimed at states’ attempts to avoid the $10,000 SALT limit
Here is what practitioners need to know about the IRS’s proposed rules that would curb the deductibility of charitable contributions that qualify for state and local tax credits.
Proposed rules would curb avoidance of SALT deduction limit
Here is what practitioners need to know about the IRS’s proposed rules that would curb the deductibility of charitable contributions that qualify for state and local tax credits.
States vary on treatment of sale of passthrough-entity interests
Rules addressing state taxation of gains or losses that arise from the sale of interests in a passthrough entity are complex and differ from state to state.
