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Our federal tax colleagues analyzed the corporate tax provisions in the Inflation Reduction Act, including the 15-percent minimum tax on corporations and the excise tax on stock buybacks.

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Read More: Inflation Reduction Act of 2022 Includes New Corporate Tax Provisions (pillsburylaw.com)

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The New Jersey Supreme Court upheld a lower court decision that Jersey City’s payroll tax New-Jersey-Seal-300x300was not a facial violation of the U.S. Constitution but remanded the matter to create a factual record to evaluate an as-applied challenge to the tax.

Enacted in 2018, the Jersey City payroll tax applies to employers with payroll exceeding $2,500 in any calendar quarter and is based on the employer’s nonresident employee payroll sourced to Jersey City.  The payroll tax statute sources a nonresident employee’s payroll to Jersey City if the employee works in or is supervised from Jersey City. Continue Reading ›

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The California Court of Appeal held a nonresident S corporation shareholder’s pro rata share of gain on the sale of goodwill classified as business income by the S corporation has a California source and is subject to tax for personal income tax purposes to the extent of the S corporation’s California apportionment formula and is not sourced 100 percent to the nonresident shareholder’s domicile. Continue Reading ›

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Pillsbury SALT attorneys Zachary T. AtkinsEvan M. HammeJack Thomas Camillo discuss new tax legislation in GA.

Takeaways https://seesalt.pillsburylaw.com/files/2022/05/Georgia-StateSeal.svg_-300x300.png

  • For tax years beginning on or after January 1, 2023, affiliated groups may elect to file a consolidated Georgia income tax return without having to seek the permission of the Georgia Department of Revenue.
  • The principal benefit of filing a consolidated return is the ability to offset taxable income and losses.
  • The election is irrevocable and binding for five years.

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An administrative law judge in the New York State Division of Tax Appeals rejected the New York State Division of Taxation’s use of a look-through approach for sourcing fees paid to a broker-dealer for marketing, recordkeeping, and support services.  The April 28, 2022 determination in Matter of TD Ameritrade, Inc., confirms that such fees are properly sourced to the location of the customer responsible for payment, in this case two banks. https://seesalt.pillsburylaw.com/files/2020/04/Seal_of_New_York.svg_-300x300.png

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Pillsbury SALT Counsel Evan Hamme will be an instructor at the COST Intermediate and Advanced Income Tax School scheduled for May 15-19, 2022.cost-300x90

COST’s Intermediate and Advanced Income Tax School is being held simultaneously with COST’s SALT Basics School and Intermediate and Advanced Sales and Use Tax School in Atlanta, GA.  These programs provide learning opportunities for attendees to explore and gain a deeper understanding of SALT Income and Sales and Use Tax issues. Continue Reading ›