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).…
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…
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…
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…
Forty-four states plus the District of Columbia impose an income tax on corporations. In response to the COVID-19 pandemic, 36 of those 45 jurisdictions have established income tax relief to corporate taxpayers in the form of tax payment extensions. Of those 36, most also extended the return filing deadline and…
SeeSALT attorneys Carley Roberts & Mike Le partnered with their Pillsbury tax colleagues Nora Burke & Hannah Hollingsworth to detail the impact of COVID-19 on the IRS and States Extended Tax Payment Deadlines. Takeaways of the recent article include: The IRS announced that individuals and businesses may defer both federal…
Nebraska’s tax department has issued guidance confirming its position that IRC 965 deemed repatriation income: 1) must be included in a taxpayer’s corporate income tax base (less the IRC 965(c) deduction); and 2) does not qualify for the state’s dividends received deduction. Nebraska Dep’t of Revenue, Gen. Info. Letter 24-19-1…
On July 23-24, members of Pillsbury SALT will lead discussions at COST’s much anticipated state and local tax technology workshop in Foster City, Calif. This one-and-a-half day event promises to deliver in-depth state and local tax content tailored to technology businesses—everything from startups to long established companies. The varied presentations…