Meet Nell, the adorable new Aussie/Great Pyrenees puppy belonging to Doug Mo, Of Counsel on the SALT team in Sutherland’s Sacramento office. Nell was rescued along with her mother and six brothers and sisters from a woodpile by Big Dog Rescue in Sonoma County. Since settling into her new home, Nell has been nicknamed “The
By Stephen Burroughs and Andrew Appleby
The Tennessee Court of Appeals held that the Commissioner had the authority to require Vodafone, a wireless communications provider, to use an alternative apportionment method for Tennessee franchise and excise tax purposes. Vodafone used Tennessee’s statutory cost-of-performance (COP) method to source its telecommunication service receipts. Using Tennessee’s statutory COP
By Sahang-Hee Hahn and Pilar Mata
The Illinois Department of Revenue determined that a taxpayer’s cloud computing receipts should be sourced for sales factor purposes using a market-based approach because the receipts were derived from services. The taxpayer was an information technology hosting services provider engaged in a business that focused on the delivery and
By Kathryn Pittman and Andrew Appleby
In a post-audit challenge by a taxpayer, the Virginia Tax Commissioner addressed entity classification, nexus and royalty add-back issues. The Commissioner found that the taxpayer did not provide sufficient evidence that its single member LLC was a disregarded entity or that certain entities were financial institutions. Turning to nexus,
On June 25, the Arm’s Length Adjustment Services Advisory Group of the Multistate Tax Commission met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment service. States participating in the meeting included Alabama, Florida, Georgia, Iowa, Kentucky, North Carolina, Pennsylvania and the District of Columbia. The primary focus of the
On June 25, the Arm’s Length Adjustment Services Advisory Group (the Group) of the Multistate Tax Commission (MTC) met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment service. States participating in the meeting included Alabama, Florida, Georgia, Iowa, Kentucky, North Carolina, Pennsylvania and the District of Columbia. The primary focus of the meeting was to follow up from the June 2 meeting in St. Louis.Continue Reading MTC Speaks with Potential Transfer Pricing Vendors
By Stephen Burroughs and Andrew Appleby
The Florida Department of Revenue determined that the sale of remote storage and cloud computing services, along with related data transfer fees, are information services not subject to Florida sales tax or Communication Service Tax (CST). The taxpayer’s remote storage service grants customers access to servers for data storage.
By Ted Friedman and Andrew Appleby
The South Dakota Supreme Court held that a corporation operating a hunting lodge did not owe use tax on its purchases of food, beverages and ammunition because the lodge purchased the goods for resale to the lodge’s customers in the regular course of business. The lodge offered hunting packages
On June 18, the Judiciary Committee of the U.S. House of Representatives voted in favor of H.R. 3086, the Permanent Internet Tax Freedom Act (PITFA) by a vote of 30-4. PITFA permanently extends the moratorium on state and local taxation of Internet access and “multiple” or “discriminatory” taxes on electronic commerce.
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