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Articles Posted in Income Tax

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California Lawyers Association’s 2021 Annual Income Tax Seminar

Pillsbury SALT attorneys Robert Merten and Lexi Louderback will present during CLA’s Annual Income Tax Seminar on July 15. Robert and Lexi will present on the topic, “Unraveling Metropoulos and Sourcing Sales of Intangibles under California’s Personal Income Tax Law.” They will discuss California’s personal income tax rules for characterizing…

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Connecticut’s Tax Gambit: Connecticut Considers Convenient Position on “Convenience of the Employer” Rule

The Connecticut House of Representatives is considering multiple proposals that would permit Connecticut residents and part-year residents to take credits for tax paid to other states while working from Connecticut during the pandemic.  Connecticut law currently allows credits for tax paid to another state only if: (1) the individual was…

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TEI’s Wisconsin Chapter Meeting

Pillsbury SALT attorneys Carley Roberts, Zachary Atkins, Nicole Boutros and Evan Hamme will present during Tax Executive Institute’s Wisconsin Chapter Meeting on February 18. The webinar will begin at 1:00pm CT and feature the following presentations: Market Based Sourcing: Developing a Multistate Approach (Carley Roberts & Nicole Boutros) SALT Implications of…

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How to Be Reasonable When Reasonably Approximating the Market: Part I

Partner Carley Roberts and counsel Robert Merten III authored Part 1 of a multi-part series in Tax Notes State’s SeeSALT Digest to review the landscape of market-based sourcing rules and provide an in-depth focus on various states’ use of reasonable approximation. Read more here.

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Delaware State Court Strikes Down NOL Limitation, Presenting Refund Opportunity

A Delaware state court invalidated the Delaware Division of Revenue’s policy limiting net operating loss (NOL) deductions for members of federal consolidated groups, holding that the policy violated the Uniformity Clause of the state constitution. Verisign, Inc. v. Director of Revenue, No. N19C-08-093 JRJ (Del. Super. Ct. Dec. 17, 2020).…

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California Legislature Passes Governor Newsom’s Proposal to Suspend California Net Operating Loss Deductions and Limit Tax Credits during 2020 – 2022

SeeSALT partners Jeff Vesely, Craig Becker, Carley Roberts and Breann Robowski break down Governor Newsom’s proposed tax legislation, recently passed by the California Legislature, to raise additional income tax revenue to assist in balancing the California budget. (AB 85). The Senate and Assembly each achieved the two-thirds majority vote required for…

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Mississippi Supreme Court Holds Tolling Provision Applies to Department, Not Taxpayers

The Mississippi Supreme Court rejected a taxpayer’s corporate income tax refund claim as untimely, holding that the timely issuance of a notice of examination and commencement of an examination tolled the statute of limitations for the Department of Revenue to make an assessment or effect a refund, but not for…

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COVID-19: Comprehensive Coverage of State Income Tax Relief as of April 13, 2020

State income tax relief in the form of tax return filing and tax payment extensions, and the deployment of related administrative guidance, has evolved rapidly in the last several weeks in the face of the COVID-19 crisis. Of the 45 jurisdictions, including the District of Columbia, that impose an income…