What do you think are the top issues/topics in state taxation today?
- State income tax reform/response to federal tax reform (which covers a wide variety of issues - depreciation, foreign income, dividends, charitable contributions, NOLs, Domestic Production Deduction, Sec. 199A, M&E, interest expenses, Sec. 118, related party expenses, deemed repatriation, like-kind exchange repeal, Sec. 179 expense, R&E expenses amortization)
- Wayfair Supreme Court Case regarding sales tax nexus/collection obligations/possible overturn of Quill/physical presence
- State taxation of foreign income
- Market-based sourcing impact (continuing trend)
- Alternative apportionment (is it all alternative?)
- Management & utilization of NOLs / 382 NOL issues
- Combined reporting vs. separate reporting
- Single-sales factor apportionment impacts (continuing trend)
- Whether to utilize Voluntary Disclosure Agreement/Amnesty programs
- Utilizing and negotiating credits and incentives
- State income taxation of pass-through entities (new pass-through entity audit rules)
- Related party expenses / transfer pricing
- Private letter ruling requests
- Other?????
