Under a new bill signed into law on March 11, 2024, the South Carolina Department of Revenue will have to satisfy additional standards before it may force affiliated corporate taxpayers to file a unitary combined return. These new standards, enacted as part of Senate Bill 298, are expected to rein…
In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator. First, the OTA rejected the “matching principle” included in FTB Ruling 2006-01, and supported its holding based primarily on the plain language of Cal. Rev. & Tax.…
SALT partners Zachary Atkins and Evan Hamme will speak at COST’s upcoming Spring Conference. This three-and-a-half day conference will bring multistate tax professionals together and will provide updates on key SALT issues and insights regarding state tax trends and opportunities. Join Zack and Evan as they speak on the following…
The California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA) and California Employment Development Department (EDD) announced tax relief for certain California counties affected by severe winter storms. The FTB automatically extended the filing and payment deadlines for businesses and individuals in San Diego County (only),…
The Supreme Court of Ohio has held the Ohio legislature did not violate the Due Process Clause of the U.S. Constitution by directing an Ohio citizen to pay taxes to the municipality where the employee’s principal place of work was located rather than to where the employee actually worked. During…
SALT attorney Aruna Chittiappa will speak at TEI’s 2024 Midyear Conference on March 19. Join Aruna as she presents on the topic “Local Tax Update” on March 19 at 10:00am, joined by Nicole Johnson of Blank Rome, Chris Streit of Tax Advisors Group and Howard Grindle (moderator) of ISS. TEI…
SALT partner Evan Hamme will speak at PLI’s Hot Topics in State and Local Tax 2024. During this half-day program, presented by PLI, leading state and local tax practitioners will address the developments and trends currently impacting the state/local tax landscape. Join Evan Hamme and Jessica Morgan (EY) at 9:15am…
SALT partner Carley Roberts will moderate a panel at this year’s ABA-IPT Advanced Sales and Use Tax Seminar. The Advanced Sales and Use Tax Seminar is one of three seminars hosted annually by the Institute for Professionals in Taxation and the ABA Section of Taxation. Featuring practitioners from around the…
A California trial court denied the Franchise Tax Board’s (FTB) motion to vacate and modify the judgment declaring FTB Technical Advice Memorandum (TAM) 2022-01 and FTB Publication 1050 invalid underground regulations adopted in violation of the Administrative Procedure Act. Seeking to limit the scope and effect of the court’s…
The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the partnership’s underlying operations. In the Matter of Greenberg, the taxpayer was a New York resident partner…