State and Local
2016 State Tax Bellwethers — Some Cautionary Notes
Commerce is changing – and, not surprisingly, the state and local tax milieu is shifting as well – so taxpayers need to be on their toes
In 2016 several states have used a variety of tools in an attempt to manage challenges that plague all states. From contesting established United States Supreme Court precedents to making broad-sweeping statutory interpretations of state laws, the landscape of state and local tax is shifting to address the evolution of… Read more »
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 »
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 »
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 »
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 »
Question: How Can Companies Take Advantage of Digital Assets With No Tax Impact? Digital-asset-based loyalty and reward programs allow companies to create a…
The Rise of the Excise Tax In August 2022, Public Law No. 117-169—commonly called the Inflation…
Prepare for Public Country-by-Country Reporting With public country-by-country reporting (CbCR) on the horizon, companies with…
Who Is the Customer? Compared to the complexity of cost-of-performance (COP) sourcing of services…
Navigating Tax Risk in the Modern Era: Why Tax Technology Is Essential In today’s ever-changing tax world, managing the organization’s tax risk…
An Exciting Year Ahead It is a great honor for me to serve as…