On April 5, 2024, the New Jersey Division of Taxation issued guidance discussing New Jersey’s adoption of the federal centralized partnership audit regime enacted as part of the federal Bipartisan Budget Act of 2015, P.L. 114-74. The guidance was released over a year after the Senate and General Assembly of…
Articles Posted in Taxable Income
Everything in its Place: New Mexico Hearing Officer Finds Markup for Out-of-State Service is Exempt, While Reimbursements for New Mexico Employee Payroll are Taxable
A New Mexico Hearing Officer found that Gross Receipts Tax does not apply to a taxpayer’s markup for services performed outside New Mexico, but the taxpayer’s reimbursements for payroll to New Mexico employees are taxable New Mexico receipts. In Protest of Talbridge, the taxpayer was a Texas employment agency with…
U.S. Solicitor General Recommends the Supreme Court Decline New Hampshire v. Massachusetts
On May 25, the U.S. Solicitor General filed its highly anticipated brief in New Hampshire v. Massachusetts and recommended that the Court decline jurisdiction over the case. Although the ultimate decision is yet to be issued, the U.S. Supreme Court generally follows the Solicitor General’s recommendations after, as here, the Court requests…
Maryland Court of Appeals Rejects First Amendment Challenge to Local Tax on Outdoor Advertising Services
On February 15, 2021, the Maryland Court of Appeals issued a decision in Clear Channel Outdoor, Inc. v. Director, Department of Finance of Baltimore City, Case No. 24-C-18-001778 (Md. 2021), upholding the constitutionality of a local ordinance that imposes an annual excise tax on businesses selling advertising space on off-site…
Maryland Becomes First U.S. State to Enact Controversial Digital Advertising Tax to Immediate Challenge
On February 12, 2021, Maryland legislators voted to override Gov. Larry Hogan’s (R) veto of H.B. 732, making Maryland the first state in the nation to impose a digital advertising tax. While Maryland’s enactment of the bill is a first, other states have impending digital advertising tax bills, such as…
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…
State Tax Tribunals – Perspectives from Both Sides of the Bench
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.