In a decision marked “not precedential,” the OTA held 100 percent of repatriated dividends must be included in the taxpayer’s sales factor denominator.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.…
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…
On April 3, 2020, New York State enacted the 2021 fiscal year budget (Budget). The Budget contains several tax measures including decoupling from taxpayer relief provisions of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The CARES Act was signed into law on March 27, 2020 with the…
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…
Carley Roberts presents on “The Taxation of Section 965 Deemed Repatriation” at COST’s Spring Audit Session & Income Tax Conference 2019 on May 1.
Three years ago, the U.S. Supreme Court invalidated a portion of Maryland’s personal income tax scheme on grounds that it violated the dormant commerce clause of the U.S. Constitution. In Comptroller of the Treasury of Maryland v Wynne, the Court held that Maryland’s credit mechanism for income taxes paid to…
On February 8, Jeffrey Vesely presents “Income Tax – TCJA and Other SALT Matters” during Tax Executives Institute’s New England Chapter Meeting.
On January 29, Carley Roberts presents “Federal-State Tax Conformity after the TCJA” during Tax Policy Center’s How Are States Responding to the Tax Cuts and Jobs Act? Conference.
(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…
On November 16, Carley Roberts presents “Federal Tax Changes Rocking the SALT Landscape” during Tax Executives Institute’s New Jersey All-Day Seminar.