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Pillsbury SALT attorney Zachary Atkins will be presenting at the 29th Annual Paul J. Hartman State and Local Tax Forum on October 21. hartman-300x101

Zachary is partnering with Richard Cram (Multistate Tax Commission) and Joe Garrett (Deloitte Tax LLP) to present on the topic, “Market Sourcing and Factor Presence Nexus Trends.” The speakers in this session will discuss trends regarding states’ adoption of market-based sourcing of services and factor presence nexus standards, constitutional issues raised by those trends, as well as P.L. 86-272 concerns.

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The Pennsylvania Governor signed H.B. 1342 to enact changes to the state’s corporate income tax.[1]  Pennsylvania-PA-State-SealThe legislation modifies the corporate income tax in three ways: (1) adopts a bright-line economic nexus standard; (2) adopts market sourcing for receipts from intangibles; and (3) reduces the corporate tax rate and gradually continues to reduce the rate over the next eight years. Continue Reading ›

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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 ›