State and Local

States Fine-Tune Market-Based Sourcing Rules Through Regulation
The devil is in the details in this complex, emerging issue

In 2015, the rubber met the road, and states began to accelerate the adoption of detailed regulations to accompany what is often vague statutory language to source receipts from the sale of services and intangibles based on the location of the “market.” In this article, we survey the key proposed… Read more »

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Procedural State Tax Issues: Part II
Coordinating Multistate Litigation

Managing state tax controversies is a complex task that involves an understanding of substantive and procedural rules that vary significantly by jurisdiction. Part I of this article, published in the May/June issue of Tax Executive, explored considerations for selecting the best forum for litigation. Part II of this article addresses… Read more »

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Procedural State Tax Issues: Part I
Finding the Best Forum

Managing state and local tax controversies is not an easy task. In addition to understanding the differences between the substantive laws applied in each jurisdiction, multistate taxpayers also need to understand the differences in procedural rules governing those disputes. In this two-part article, we address the most common issues that… Read more »

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Intercompany Transactions: Current State Tax Developments
Nexus and documentation are key issues in understanding the current intercompany transaction legal landscape

Intercompany transactions can be used to shift income from entities with a physical nexus in many states to a related member with a limited nexus in favorable taxing jurisdictions. In moving to combat the benefits received from such intercompany transactions, states tend to employ one or more of the following… Read more »

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