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Pillsbury SALT attorneys Zachary T. AtkinsMarc A. SimonettiEvan M. HammeJack Thomas Camillo discuss new tax legislation in GA.

Takeaways https://seesalt.pillsburylaw.com/files/2022/05/Georgia-StateSeal.svg_-300x300.png

  • For tax years beginning on or after January 1, 2023, affiliated groups may elect to file a consolidated Georgia income tax return without having to seek the permission of the Georgia Department of Revenue.
  • The principal benefit of filing a consolidated return is the ability to offset taxable income and losses.
  • The election is irrevocable and binding for five years.

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An administrative law judge in the New York State Division of Tax Appeals rejected the New York State Division of Taxation’s use of a look-through approach for sourcing fees paid to a broker-dealer for marketing, recordkeeping, and support services.  The April 28, 2022 determination in Matter of TD Ameritrade, Inc., confirms that such fees are properly sourced to the location of the customer responsible for payment, in this case two banks. https://seesalt.pillsburylaw.com/files/2020/04/Seal_of_New_York.svg_-300x300.png

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Pillsbury SALT Counsel Evan Hamme will be an instructor at the COST Intermediate and Advanced Income Tax School scheduled for May 15-19, 2022.cost-300x90

COST’s Intermediate and Advanced Income Tax School is being held simultaneously with COST’s SALT Basics School and Intermediate and Advanced Sales and Use Tax School in Atlanta, GA.  These programs provide learning opportunities for attendees to explore and gain a deeper understanding of SALT Income and Sales and Use Tax issues. Continue Reading ›

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Pillsbury SALT partner Marc Simonetti will present during COST’s 2022 Income Tax Conference on April 27.

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COST’s Income Tax Conference is a two-and-a-half-day conference taking place from April 25 – 28, 2022 at the Grand Hyatt in Denver, Colorado. The conference combines technical and policy presentations from professionals with a focus on current income and franchise tax issues.

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https://seesalt.pillsburylaw.com/files/2022/03/Seal_of_Texas.svg_-300x300.pngThe Texas Supreme Court issued a decision holding that service receipts are sourced to the physical location of the taxpayer’s personnel or equipment that performed the service for which the customer paid. The decision resolves disagreement regarding the proper interpretation of a Texas franchise tax apportionment statute that addresses the sourcing of service receipts. The statute sources a service provider’s receipts to Texas to the extent the service is “performed” in Texas. The taxpayer argued that its receipts from sales of satellite radio programming subscriptions were properly sourced to the location where its personnel and equipment performed the radio production and transmission services necessary for its radio programming (“origination sourcing”). The Comptroller interpreted the apportionment statute to source service receipts to Texas if the “receipt-producing, end-product act” takes place in Texas, which the Comptroller argued occurred where each subscriber’s radio received and decrypted the taxpayer’s radio signal (“destination sourcing”).

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https://seesalt.pillsburylaw.com/files/2022/02/1200px-Seal_of_Alabama.svg_-300x300.png

The Alabama Tax Tribunal held the taxpayers’ wholesale sales of fuel that entered and exited the state via the Colonial Pipeline were subject to the state’s wholesale oil license fee. The sales in question were made to Alabama license holders and involved fuel imported from out-of-state. The fuel would either enter Alabama from out-of-state through the Colonial Pipeline or be injected in the pipeline at a point in Alabama. In either instance, the fuel was bound for final movement out of Alabama with there being no subsequent point in Alabama where the fuel could exit the pipeline.

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