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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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