don't let uncertain state tax positions surprise your company or client

Uncertain state tax positions are everywhere. Your company or your clients likely have them. Have you identified them? Have you addressed them?

During ‘busy season’ or ‘tax season, state tax questions often arise or lay there quietly in the background while federal tax issues get all of the attention.

State tax issues or the state tax impact of an issue or transaction is generally considered after the federal tax impact is addressed.

Non-state tax experts are sometimes just too busy to give state tax issues adequate time before a deadline. In other situations, non-state tax experts may simply view a state tax issue as less complicated than it really is. Consequently, state tax issues may not get addressed before the original due date of the returns and may only get addressed in late summer or early fall prior to the extended due date. This often creates a time crunch for uncertain state tax positions to get adequately addressed. That's one of the problems.

The other problem is that most state tax issues are more complex than they appear. A high-level overview or two hours of research won't cut it, especially when you are trying to determine the state tax impact of a large transaction or adequately source the gain on a sale of a partnership interest to the right state or states.

What are these 'uncertain state tax positions'?

Where can they appear?

The following is a summary of some of the areas or items that create uncertain state tax positions on state income tax returns:

1. Structure - intangible holding companies; REIT / RIC; buy / sell companies, management / services companies; state-specific structures; captive insurance companies; finance companies; factoring companies; check-the-box entities; pass-through entities;

2. Transactions - mergers, acquisitions, divestitures; repatriation dividends; reorganizations; bankruptcy issues;

3. Nexus - P.L. 86-272; economic nexus; attribution of activities; forced combination; foreign company nexus despite no permanent establishment in U.S.;

4. Filing Options - separate, nexus combined, hybrid nexus combined, unitary combined (waters-edge, worldwide); consolidated;

5. Apportionment - ability to apportion income; choice of formula; throwback / throwout; joyce vs. finnegan; sales factor sourcing (destination, market-based sourcing, cost of performance, commercial domicile, location of payor);

6. Tax Base - business v.s nonbusiness income vs. separate accounting; Internal Revenue Code (IRC) conformity; related party addbacks; depreciation adjustments; dividends received deduction conformity; transfer pricing; foreign source income; state specific additions/subtractions;

7. Treatment of Partnerships - entity vs. aggregate theory; unitary (tax base / factor flow-up) vs non-unitary (allocation); sale of partnership interest;

8. Tax Attributes - NOLs (pre-apportioned vs. post-apportioned); IRC Sec. 382 limitations; survivor / non-survivor limitations; credits (claw-backs; compliance with agreements);

How do you ensure these items are addressed adequately?

• Get a state tax expert involved early.

How do you know when your client has any of these issues?

• Create a checklist that helps you identify clients or when your company may have these issues. That checklist may be based on the amount of sales a company has, the amount of taxable income, the number of states they file returns in (or the number of states they should file in), or if they have a specific structure or entered into a transaction that obviously needs reviewed.

There are multiple checklists you could create, the key is to make one that works for your company or firm that doesn't slow down the compliance process, but does allow you to reduce risk and adequately document a supportable, defendable or winnable position.

I hope you have a great tax season (now and in the fall). I hope all of your uncertain state tax positions achieve as much certainty as they can and are adequately addressed and documented.

who or what is 'rocking the boat'?

Usually 'rocking the boat' is perceived to be a bad thing, but 'rocking the boat' can be a good thing. Let me explain.

If you are riding in a boat heading into a storm and the boat starts rocking, that is usually a bad thing or scary. The boat is rocking to due to some external force or environmental change.

If someone on your boat gets up and starts jumping around without any explanation and you can't stop them or talk with them, that is usually a bad thing.

But if the the captain of the boat purposely turns the boat, changes direction and heads into the storm, then the rockiness of the boat is a good thing. It means the boat is going in the right direction. A strategic, purposeful direction. The rockiness is part of the process of reaching the chosen destination.

If someone on the boat gets up and voices a concern with the current direction of the boat, and makes a valid point why the boat should change course, the rockiness of the boat is a good thing. A necessary thing.

I'm sure we could keep going with this analogy or you could make up better analogies, but you get the point. Change, upheaval, incurring resistance or turbulance is sometimes a necessary or required part of the process of achievement or improvement.

HOW DOES THIS APPLY TO STATE TAXES?

2024 just began. January already gone. State governments have started or will be starting their legislative sessions. Proposals are flying all around. This is in addition to the state tax law changes that were enacted last year that became effective in 2023 or as of January 1, 2024. On top of the state legislative proposals, we also have federal legislation that is moving through the House and Senate that will have ripple effects on the states regarding research and development expenses and other items (appears to have a high probability of passing). The SALT CAP (i.e., state tax deduction limit of $10,000) is proposed to double to $20,000 (based on commentary, this legislation has a low probability of passing). As with all federal tax legislation, some states automatically conform, and some states don't conform until they specifically say they do.

All of these changes can 'rock the boat' of your business.

These are external changes that you don't have control over. You may be able to influence them (or some people may be able to), but for most companies, their 'boats' get rocked and they have to learn how to change course to find calmer waters.

Some state tax issues or items that are currently being challenged or expected to become bigger issues in 2024 that could 'rock your boat':

1. More states to adopt state income tax exconomic nexus thresholds

2. The protections of P.L. 86-272 continue to be challenged and worked around.

3. Gross receipts taxes (Ohio, Washington, Tennessee, Oregon, Nevada) continue to change their rules.

4. Sourcing sales of services or intangibles for income tax apportionment purposes continues to be more confusing with market-based sourcing - do you source to your customer or your customer's customer?

5. How do you source the gain on the sale of your partnership interest?

6. Should my company really make pass-through entity tax (PTET) elections in all states where we can?

7. Do I really owe the California LLC fee or minimum tax based on my ownership in a California LLC?

8. Am I required to file a state income tax combined return?

9. Should I make state income tax elective consolidated return elections?

10. Will the Washington capital gains tax survive challenges and should I pay it?

11. Does everyone have economic nexus for income tax purposes if the state has no 'factor presence' threshold?

12. Can a telecommuting employee that does 'back office' functions create nexus but a telecommuting employee that solicits sales be protected by P.L 86-272?

13. Is SaaS considered tangible personal property or a service for state income tax apportionment purposes?

14. Does P.L. 86-272 apply to sales of SaaS?

15. How can a company realistically source sales of SaaS when the users are in multiple states and the buyer doesn't provide the data?

16. Are state 'throwback' rules constitutional?

17. Should market-based sourcing really create economic nexus?

I could keep going, but I will stop.

CONCLUSION

External forces will always 'rock a company's boat.' However, even if the boat isn't currently rocking, a taxpayer or a tax consultant may need to stand up in the boat to advise or ask the captain of the boat to change directions. The goal is to adapt to the wind or to change the direction of the boat so the company can move towards calmer waters or avoid the storm altogether.

Unfortunately, the constant change in federal and state tax legislation and court cases and rulings, makes it difficult for the waters to stay calm very long.

The best strategy for a company to thrive in this type of environment is to monitor changes, make informed decisions and most of all - be proactive. Don't wait until your in the middle of the storm.

You can always navigate out of the storm, but the damage to the boat will differ based on how quickly you change course.

Here's to smooth sailing.

conduct state tax "year-end" planning early, often & always

This is a Public Service announcement. Revealing a secret from the state and local tax underground. A secret that makes it difficult for companies to do business. To stay in compliance. To avoid compounding tax liabilities and interest and penalties.

What is this secret?

Wait for it . . . . . . . .

State taxes are a "moving target."

A "moving target" is defined as:

• something that moves while someone is trying to hit it

• something that is always changing

Some state tax rules don't change. Some state tax rules change at a certain time or in a certain tax year based on federal or state legislation. Some state tax rules change every year. Some state tax rules change suddenly based on a court case or ruling. Some state tax rules change without you knowing it based on a state's internal policy decision or change in interpretation of a statute or regulation.

• So how does a company plan?

• Conduct year-end planning?

• Conduct beginning of the year planning?

• Plan for acquisitions, mergers, divestitures?

Companies must stay on top of income tax laws on a tax year by tax year basis. Meaning, income tax laws are generally static for a specific tax year, but can change from year to year. Thus, tax pros should not follow "SALY" (same as last year) when preparing returns. This can lead to "IAP" (interest and penalties). With that said, there are situations when court case decisions or rulings happen that may have retroactive impact and create amended return / refund opportunities or may simply alter prospective returns.

In regards to sales tax, there are static rules but the interpretation of some of those static rules can change and are definitely not the same in every state. Sales tax rules and tax rates can change at different times of the year due to court cases, rulings and state legislation. Unlike income tax, sales tax periods are generally monthly, quarterly or annual

It's the lack of uniformity among state tax laws that creates risks and opportunities.

Some state income tax laws that may differ from state to state are:

• Economic Nexus (creating a taxable presence)

• Sales sourcing of sales of tangible property and services

• Requiring throwback of sales

• Allowing or requiring combined reporting

• Allowing a pass-through entity (PTE) to make a PTE tax election (i.e., $10,000 SALT-CAP work around)

• If PL 86-272 protection applies

• Conformity to federal international tax considerations (i.e., GILTI, FDII, deemed dividends, ECI, etc.)

• Treatment of bonus depreciation

• Treatment of disregarded entities (i.e., single-member LLCs or Q-Subs)

Some sales tax laws that may differ from state to state are related to the following:

• Sourcing of sales of services (including multiple points of use)

• Sourcing of sales to/from non-US countries

• Sales of software, SaaS, and other computer services

• Sales of information services or data processing

• Sales of services

• Sales by construction contractors

• Treatment of sellers in drop shipment transactions

• Allowable or acceptable forms of exemption certificates

• Treatment of leases (lessors and lessees)

• Width and breadth of manufacturing exemption

• Occasional sale or casual sale exemption when selling assets or business

• Treatment of repairs and maintenance (labor and parts)

• Treatment of research and development activities

• Sales to governmental and non-profit entities

I could keep going, but I think you get the point.

So what is a company supposed to do?

Depending on what stage your business is (i.e., start-up, emerging, growth, mature), I recommend you inquire of your tax professional about the state tax impacts of your business. You may only have one or a few states to deal with right now. Some of you may have 20 or more states to consider. The key is to get on top of it now. To know what you don't know so you can make informed decisions. To stop problems from growing out of control and implement proper procedures and tax decisions. Be proactive. Don't let blind spots create a compound effect of problems.

Conduct year-end state tax planning, early, often and always.

QUOTES

• "In all affairs, it's a healthy thing now and then to hang a question mark on the things you have long taken for granted." - Bertrand Russell

• "Bureacracy is the art of making the possible impossible." - Javier Pascual Salcedo

• "Knowledge is the beginning of practice; doing is the completion of knowing." - Wang Yangming

"darkness is death"

Time change. Daylight savings time. Fall back. Spring ahead. However you describe it, most (if not all of us) changed our clocks recently. We either gained an hour or lost an hour (depending on how you look at it), but one thing I do know - I've lost daylight. So I'm not sure how this is "daylight savings" time. I don't like to complain, but I just do. So I'll just say that I really like sunlight and dislike darkness. As they said in a cartoon movie I can't remember the title of right now - "Darkness is Death."

Regardless of how you feel about changing your clocks or sunlight or darkness, one thing is certain, times continue to change. The way business is conducted continues to change. New technologies are created (whether that's good or bad; or will be used for good or bad is yet to be seen). And last but not least, state tax legislation continues to change; and court cases and rulings continue to be made which ultimately create certainty and uncertainty. Wait, what? What did you just say?

Yes, new legislation, court cases and rulings create just as much uncertainty as they do certainty.

Well, that's great.

Just as each company's facts and circumstances differ, state tax laws seem to have a life of their own when the answer isn't "black and white" (which is most of the time); or when each state's laws are different. This creates a world of grey (or some may say, "darkness"). This "darkness" is why I say every state tax question is a research question. (A research question that needs to be solved by a human (not A.I., AI or artificial intelligence, just saying)).

Darkness is debilitating. It's hard to drive in the dark without headlights. It's hard to walk in the dark without a flashlight. Darkness creates fear and uncertainty. Darkness creates unknown risks. Thus, light is needed to move forward with some level of assurance and confidence.

Darkness can also create unknown opportunities. You can't see them. This requires faith. A compass. A navigator. A roadmap.

"Darkness" in the state tax world surrounds several areas and questions companies continually ask:

• what states do I need to file tax returns in?

• is what I'm selling subject to sales tax?

• which entity in my affiliated group of companies is required to file the tax return?

• if I sell my interest in this partnership, to what states do I source the gain and have to pay tax?

• I'm selling services all across the United States. How do I source those sales to each state in the apportionment factor of my income tax returns?

• do I really have to get exemption certificates from my customers?

• do I have to register with a state for sales tax purposes to provide a vendor with that state's resale exemption certificate or can I use a multijurisdictional certificate?

• am I required to file combined income tax returns or does every entity file separately?

• should I make this election or that election?

• do I qualify for these tax credits?

• do I have to collect sales tax on my total gross receipts or can I deduct costs reimbursements or costs that I flow-through and pay to someone else?

• how do I know if we really meet the requirements to be protected from a state's income tax by P.L. 86-272?

• I didn't even know that state had a gross receipts tax.

• what is a franchise tax and why is the tax base so high?

• am I really selling SaaS and does the state tax it?

• should I make a state's pass-through entity tax election? How do i quantify or model the impact? Will it be beneficial for all partners and shareholders?

• should I file a Voluntary Disclosure Agreement (VDA) or simply start filing returns?

• should I request a Private Letter Ruling (PLR)?

• should I challenge (protest) this audit assessment or simply pay it and move on?

• when can I stop filing returns in a state?

• how do I dissolve or withdraw from a state?

• is registering with a state's Secretary of State's Office the same thing as registering with a state's Department of Revenue (taxation)?

• what sales tax compliance software should I use? Should I outsource the return prep to a third-party?

I could keep going, but I think you get the point. The darkness is everywhere.

Finding the light in the state tax world is not easy.

Unlike darkness in life where you can just flip the light switch and see, darkness in the state tax world takes research and analysis and judgment based on experience. And even then, the answer may not be clear (still dark or grey).

Consequently, I think the "light" is finding the right-fit state tax consultant that you trust and like working with. Someone with not only the technical knowledge and experience, but the ability to look at an issue from 2 feet and 50,000 feet. To be technical and practical. To look at the risk and provide judgment. To reduce risk. To recommend positions with the proper level of assurance. Knowledge. Judgment. Advocacy. That is the light in the proverbial darkness. The compass. The roadmap. The flashlight. The headlight.

I hope you find the light you need to move your company and clients forward.

If you are a state tax consultant, I hope you "shine brightly."

QUOTES

"The art and science of asking questions is the source of all knowledge." - Thomas Berger

"The prize goes to the person who sees the future the quickest." - William Stiritz

"We are drowning in information and starved for knowledge." - John Naisbitt

STATE TAX KNOWLEDGE UPDATE (53 ITEMS) - AUGUST 3, 2018

The following are state tax and business developments I have curated since July 3rd, and posted in the LEVERAGE SALT LinkedIn group:

Some of the items may be on the same state/issue/topic, but they are from different sources which may give you a broader perspective to help your company or client.

1. New Jersey Closes Loophole, Increases Multi-Millionaires Rate

2. Alabama Announces Guidance in Response to Wayfair Decision

3. Michigan Provides Further Guidance on Impact of Federal Act

4. Remote Sellers Will Have Wisconsin Tax Duties Beginning October 1

5. Indiana Updates Remote Seller Guidance

6. Indiana Explains Income Taxes on Overseas Earnings

7. Enacted Louisiana law addresses the timing of expiring corporate income tax provisions

8. California OTA Issues Updated Draft of Proposed Permanent Regulations on Administration and Procedures of Appeals and Petitions for Rehearing

9. Indiana DOR Bulletin Discusses Recently Enacted Legislation, Including State Impact of IRC Sec. 965 Repatriation Provisions, GILTI, and IRC Sec. 163(j)

10. Maine Revenue Services Explains Procedures for Filing and/or Amending Returns Given State’s Nonconformity to Recent Federal Tax Law Changes

11. Pennsylvania: Bulletin Reflects New Law Reversing DOR’s Previous Policy by Allowing for Depreciation of 100% Bonus Property

12. New Jersey: New Law Requires Amnesty Program with Potential Waiver of 100% Penalties and 50% Interest

13. Massachusetts Appellate Tax Board Holds that Taxpayer is a “Manufacturer” Required to Compute its Corporate Excise Tax Liability Using Single Sales Factor Apportionment

14. New Jersey: New Law Includes Mandatory Combined Reporting Regime, Market-Sourcing Provisions, CBT Surtax, and Responses to Some Provisions of the Federal 2017 Tax Act

15. New York: Appellate Court Affirms Tax Appeals Tribunal Ruling Addressing Bank’s Treatment of NOLs

16. Vermont: New Law Updates State Conformity to Internal Revenue Code; Responds to Some Provisions of the Federal 2017 Tax Act

17. Georgia DOR Explains Exclusion for Dividends from Sources Outside the US, Including Application of IRC Sec. 965 Provisions

18. North Carolina: New Law Modifies Sourcing Language for Receipts from Intangibles for Sales Factor Purposes

19. Oregon DOR Issues Administrative Rule on New State Repatriation Tax Credit Pursuant to IRC Sec. 965 Repatriation Income for Tax Year 2017

20. Connecticut Issues GILTI Guidance

21. North Carolina Changes Intangible Property Sourcing Rules

22. MTC Adopts Apportionment Regulation Amendments

23. Delaware Imposes Tax on Series LLCs

24. Utah Enacts Deferred Foreign Income Changes

25. Florida DOR Holds that Taxpayer May Include Certain Intercompany Sales with Foreign Affiliates in its Sales Factor

26. New Jersey Division of Taxation Explains Upcoming Amnesty Program with Potential Waiver of Penalties, Reduced Interest, and Non-Participation Penalties

27. Alaska: New Law Requires Public Utilities to Use MTC Three-Factor Apportionment Formula for Corporate Income Tax Purposes

28. Connecticut: New Guidance Issued on Treatment of GILTI for Corporation Business Tax Purposes

29. Minnesota DOR Discusses How 2017 Federal Tax Act May Affect Business Tax Returns for Tax Year 2018

30. Rhode Island DOT Comments on Some State Tax Impacts of the Federal 2017 Tax Act

31. Utah: New Law Clarifies Previously Enacted Legislation Involving IRC Sec. 965 Deferred Foreign Income, and Revises NOL Provisions

32. Rhode Island Adopts C Corp IRC Sec. 965 Regulations

33. California Taxpayer Cannot Force Retailer to Seek Sales Tax Refund

34. Minnesota Hosting SST Meeting to Discuss Wayfair

35. Maryland Issues Wayfair Guidance

36. Indiana Wayfair FAQ Page Talks Enforcement

37. SST Meets to Discuss Wayfair

38. Texas Provides Guidance on Wayfair Decision

39. Wayfair Decision Does Not Affect Rhode Island Remote Sellers

40. Minnesota Sets Remote Collection Date

41. Indiana Explains Impact of Wayfair

42. Nebraska Issues Guidance for Remote Sellers

43. Utah Enacts Economic Nexus Law

44. Alabama Explains Impact of Federal Tax Cuts and Jobs Act

45. Michigan Issues Sales Tax Economic Nexus Guidelines

46. MTC Adopts Two Amended Model Rules Pursuant to Section 18 Alternative Apportionment Regulatory Project

47. Alabama DOR Issues Preliminary Guidance on Some State Impacts of the Federal 2017 Tax Act

48. Delaware: New Law Imposes Annual Tax on State-Registered Series LLCs

49. Michigan Appellate Court Affirms Disallowance of MBT Modified Gross Receipts Tax Base Deduction for Purchased Services

50. Vermont Department of Taxation Issues Certain Guidance on Federal 2017 Tax Act, Specifically the Inclusion of IRC 965 Income on State Returns

51. Arkansas DFA Says Remote Sellers Should Register and Collect Tax Pursuant to Recent US Supreme Court Decision that Overrules Quill

52. Kentucky DOR Updates Post- Wayfair Comments; Announces October 1 Enforcement Date and Reiterates Prospective Implementation

53. Nebraska DOR Comments on Recent US Supreme Court Decision that Overrules Quill, Including January 1, 2019 Enforcement Date and Promise of “No Retroactivity”

The above represents 'general curating' of state tax developments into one spot. If you still feel overwhelmed by the volume of state tax developments, please consider my 'custom curating' service. Meaning, clients hire LEVERAGE SALT to daily curate state tax developments relating to a specific industry, state(s), tax type and issue. You can make it as granular as you prefer. This allows you to reduce information overload, and only get the information you need to help your clients or company. This service is provided on a fixed-fee or subscription basis. Contact me at strahle@leveragesalt.com.

STATE TAX KNOWLEDGE UPDATE (54 ITEMS) - JULY 3, 2018

The following are state tax and business developments I have curated since June 11th, and posted in the LEVERAGE SALT LinkedIn group:

Some of the items may be on the same state/issue/topic, but they are from different sources which may give you a broader perspective to help your company or client.

1. High Court Will Not Review Pennsylvania NLC Carryover Decision

2. North Carolina Budget Bill Makes Major Tax Changes, Updates Conformity

3. Colorado Issues IRC Sec. 965 Repatriation Transition Tax Guidance

4. Connecticut Issues Guidance on Pass-Through Entity Tax

5. Connecticut Issues Guidance on Bonus Depreciation Changes

6. Hawaii Enacts Sales Thresholds for Sales Tax

7. Hawaii Updates IRC Conformity for 2018

8. Chicago Tax on Streaming Services Upheld

9. Virginia Enacts Biennial Budget Legislation

10. Are High Court Tax Precedents Set in Stone After 25 Years?

11. DON'T PANIC - Physical Presence No Longer Matters in Determining Whether A Company is Required to Collect Sales Tax

12. North Dakota Remote Seller Thresholds Take Effect With Quill Overturn

13. Louisiana Enacts Remote Seller Law

14. Minnesota Offers Wayfair Guidance

15. What will non-streamlined sales tax states do??

16. STOP THE USE TAX NOTICE AND REPORTING LAWS!!!!

17. California OTA Issues Revised Draft Proposed Permanent Regulations on Administration and Procedures of Appeals and Petitions for Rehearing

18. Louisiana: New Law Clarifies that Certain Reductions and/or Suspensions of Tax Benefits, Credits, and Exemptions Enacted via 2015 Legislative Changes were Temporary

19. North Carolina: New Law Updates State Conformity to IRC, Responds to Some Provisions of the Federal 2017 Tax Act, and Revises Sales Factor Sourcing Rules

20. US Supreme Court Denies Taxpayer’s Request to Review 2017 Pennsylvania Supreme Court Ruling on NOL Carryovers

21. Rhode Island Division of Taxation Releases Guidance on Treatment of IRC Sec. 965 Income for C Corporations, and Accompanying Proposed New Regulation

22. Texas Appellate Court Holds that Taxpayer Provides Services Rather than “Goods” for Purposes of Calculating Deductible Costs of Goods Sold under Franchise Tax

23. Alabama Issues IRC Sec. 965 Repatriation Income Guidance

24. Decoupling Bill Sent to New Jersey Governor

25. New Jersey Legislature Passes Tax Amnesty Bill

26. Rhode Island Budget Bill Amends Personal Exemptions, Credits

27. Connecticut Creates Deduction for Venture Capital Income

28. Iowa Offers Wayfair Guidance

29. Louisiana Decreases Sales Tax Rate

30. New Jersey Legislature Passes Alternative Surtax and Decoupling Bill

31. Massachusetts Bill Creates Family and Medical Leave Payroll Tax

32. Remote Sellers Not Yet Required to Collect Tax From South Dakota Buyers

33. Vermont’s Remote Seller Law Takes Effect July 1

34. Corporate Close-Up: Colorado Latest State to Enact Market-Based Sourcing

35. Hawaii Explains Nexus Thresholds

36. Kentucky Provides Wayfair Guidance

37. Rhode Island Outlines Remote Seller Registration Options

38. Vermont Reduces Rates, Updates IRC Conformity

39. Idaho Is Reviewing Impact of Wayfair Decision

40. New Hampshire Responds to Wayfair Decision

41. Pennsylvania Decouples Corporate Income Tax from Federal Bonus Depreciation

42. NCSL says states should ensure that they are fully prepared before begin enforcing their sales tax laws on remote sellers

43. New Jersey Enacts Tax Amnesty Bill

44. New Jersey Enacts Surtax, Combined Reporting, and Decoupling

45. Colorado DOR Discusses State Treatment of Foreign Earnings Subject to New Federal Transition Tax under IRC §965

46. Hawaii: New Law Updates State Conformity to Internal Revenue Code, Responds to Some Provisions of the Federal 2017 Tax Act

47. Illinois DOR Issues Proposed Amended and New Rules on Prior Year NOL Suspensions and Special NOL Computation Rules

48. New York: Draft Proposed Article 9-A Franchise Tax Regulations Issued on Corporations Subject to Tax

49. New Jersey Appellate Court Affirms that IRC Tax Attribute Reductions May Not be Reversed

50. Alabama DOR Issues Additional Guidance on IRC Sec. 965 Transition Tax’s Impact on State Tax Returns

51. California: FTB Explains New Policy Prohibiting Certain Ex Parte Communications Involving Alternative Apportionment Petition Hearings

52. Rhode Island: New Law Grants State Tax Administrator Additional Authority in Light of Federal 2017 Tax Act

53. Louisiana: New Law Includes Tax Rate Reduction and Various other Changes

54. Rhode Island: New Law Imposes Tax on Sales of Software as a Service (SaaS)

The above represents 'general curating' of state tax developments into one spot. If you still feel overwhelmed by the volume of state tax developments, please consider my 'custom curating' service. Meaning, clients hire LEVERAGE SALT to daily curate state tax developments relating to a specific industry, state(s), tax type and issue. You can make it as granular as you prefer. This allows you to reduce information overload, and only get the information you need to help your clients or company. This service is provided on a fixed-fee or subscription basis. Contact me at strahle@leveragesalt.com.