(This article originally appeared in the Journal of Multistate Taxation and Incentives, Vol. 28, No. 9.) The question of whether or not an individual is a resident of a particular state has always been an important issue in the area of state personal income taxation. California, because of its top marginal…
In SeeSALT Digest, members of our team examine important issues in play in the State and Local Tax arena. In “Ill-Fated Litigation: Exhausting Administrative Remedies and De Novo Review,” published in State Tax Notes, colleagues Carley Roberts and Jessica Allen take a look at two of the more dangerous pre-litigation…
On November 16, Carley Roberts presents “Federal Tax Changes Rocking the SALT Landscape” during Tax Executives Institute’s New Jersey All-Day Seminar.
On August 15, Craig Becker, Breann Robowski and Robert Merten present during Council on State Taxation’s 2018 Property Tax Workshop.
On July 31, Breann Robowski presents “Life in the Fast Lane … New Rules of the Road for Internet Regulation: How Do Changes in Net Neutrality Impact Property Taxes?” during the Center for Management Development’s 48th Annual Taxation Conference Appraisal for Ad Valorem Taxation Conference 2018.
TAKEAWAYS The Court holds that the South Dakota law satisfies the Commerce Clause “substantial nexus” requirement based on the “economic and virtual contacts” with the State. The Wayfair decision does not prohibit the retroactive application of this new standard for Commerce Clause “substantial nexus.” The decision strikes a blow to the…
(This article was originally published by Law360.) California’s A.B. 2731 seeks to accomplish what the federal Tax Cuts and Jobs Act did not, namely, to close the carried interest “loophole.” Currently making its way through state assembly committees, AB 2731 would impose an additional 17 percent tax on interest income derived…
On April 20, Carley Roberts presents “State Tax Tribunals – Perspectives from Both Sides of the Bench” during Council on State Taxation’s 2018 Income Tax Conference.
On April 13, Pillsbury senior counsel Richard Nielsen presents “Sales Taxation of Digital Commerce in the United States” during the the “Digital Economy in the Crosshairs” panel session at the American Bar Association’s 18th Annual Tax Planning Strategies U.S. and Europe Conference.
(Note this originally appeared in March 26, 2018, edition of State Tax Notes) Nearly every state that imposes a corporate income tax includes a sales factor in its apportionment formula. Generally, the sales factor in computed by comparing a taxpayer’s “in-state” sales to its total sales. Determining in-state sales of…