SeeSALT BlogPillsbury SALT attorneys Carley Roberts, Marc Simonetti, Zachary Atkins, Nicole Boutros and Evan Hamme will present during Tax Executive Institute’s Wisconsin Chapter Meeting on February 18.
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TEI’s Wisconsin Chapter Meeting
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Articles Posted in SALT Impact of TCJA
New York FY 2021 Budget Bill Decouples from CARES Act Taxpayer Relief Provisions
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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 primary objective to provide economic relief and greater liquidity to American taxpayers facing hardship because of the COVID-19 crisis. Specifically, the Budget decouples from taxpayer favorable provisions in the CARES Act including the increase to the permitted business interest expense deduction and the beneficial NOL provisions. As a result, New York taxpayers will not receive the benefit of the CARES Act relief provisions for New York tax purposes. Continue Reading ›
Nebraska Clarifies Treatment of IRC 965 Repatriation Income
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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 (Sept. 13, 2019).
“The Taxation of Section 965 Deemed Repatriation”
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Carley Roberts presents on “The Taxation of Section 965 Deemed Repatriation” at COST’s Spring Audit Session & Income Tax Conference 2019 on May 1.
Commerce Clause Decisions Open Door for TCJA-Related Challenges
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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 other states impermissibly discriminated against interstate commerce because it allowed a credit against state taxes paid but not county taxes, resulting in double taxation on some income earned outside the state.
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“Income Tax – TCJA and Other SALT Matters”
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On February 8, Marc Simonetti and Jeffrey Vesely present “Income Tax – TCJA and Other SALT Matters” during Tax Executives Institute’s New England Chapter Meeting.
“Federal-State Tax Conformity after the TCJA”
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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.
Revisiting California Tax Residency after the TCJA
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(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 personal income tax rate of 13.3 percent1, and the large number of high-wealth individuals living in the state, always has been one of the most significant jurisdictions for this issue. Indeed, California, at 13.3 percent, currently has the highest personal income tax rate of any state.2 The significance of the high California rate, and the residency issue in general, recently has taken on added significance as a result of two federal tax law changes.
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“Federal Tax Changes Rocking the SALT Landscape”
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On November 16, Carley Roberts and Marc Simonetti present “Federal Tax Changes Rocking the SALT Landscape” during Tax Executives Institute’s New Jersey All-Day Seminar.
Fund Managers Face Tax Hike If California Passes AB 2731
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(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 from investment management services on taxpayers subject to California’s personal income tax law.