In this episode of the SALT Shaker Podcast, Eversheds Sutherland Partner Tim Gustafson joins Associate Jeremy Gove for a deep dive into California’s market-based sourcing regulation.
Together they discuss various interpretations of and proposed amendments to the regulation offered over the past six years, and how the interpretations and amendments might affect taxpayers.
They wrap
In the pending-precedential decision Appeal of Southern Minnesota Beet Sugar Co-op., the California Office of Tax Appeals (OTA) ruled that payroll, property and sales that generated deductible agricultural cooperative income under Cal. Rev. & Tax. Code Section 24404 must be included in the taxpayer’s corresponding payroll, property and sales factors.
The California Franchise Tax
In this installment of A Pinch of SALT for Tax Notes State, Eversheds Sutherland Partner Tim Gustafson reviews California’s market-based sourcing regulation, various interpretations of and proposed amendments to the regulation offered over the past six years, and how the interpretations and amendments might affect taxpayers.
Read the full article here.
In the latest episode of the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove is joined by SALT Partner Tim Gustafson to discuss the ins and outs of the one-of-a-kind settlement process in California.
Before diving into specific considerations for taxpayers, Jeremy and Tim provide an overview of the settlement process itself, including a discussion
The North Carolina Department of Revenue issued a letter ruling that concluded an online platform owner and administrator was not a marketplace facilitator because it neither collected nor otherwise processed payment for any items sold on the website. The taxpayer requesting the ruling was an affiliate of original equipment manufacturers “OEMs), and operated a platform
The pending precedential Office of Tax Appeal’s (OTA) decision of Appeal of L. Smith, OTA Case No. 20036033 (Dec. 7, 2022) concerned whether California could impose income tax on a nonresident’s distributive share of gain from the sale of an interest in a timeshare developer operating in California as a limited liability company (Timeshare).
The Missouri Department of Revenue recently published remote seller and marketplace facilitator FAQs regarding the implementation of the state’s remote seller and marketplace facilitator use tax collection requirement. Beginning January 1, 2023, vendors (including marketplace facilitators) selling tangible personal property into Missouri must collect use tax on the retail sale price if the vendor’s gross
On November 4, 2022, the Washington Department of Revenue adopted WAC 458-20-290, a regulation explaining the state’s workforce education investment surcharge on select advanced computing businesses. The regulation defines a select advanced computing business as “a person who is a member of an affiliated group with at least one member of the affiliated group engaging
On October 15, 2022, the Utah State Tax Commission published a proposed amendment to its rule governing the taxation of custom software for sales and use tax purposes, clarifying that the sale, rental or lease of custom computer software constitutes a sale of personal services that is not subject to tax, regardless of the form
The Taxation of Remote and Internet-Based Computer Software Products and Services Study Committee (the “Committee”) was empaneled by the Mississippi Legislature to examine and develop recommendations regarding the taxation of remote and internet-based computer software products and services following the Mississippi Department of Revenue’s (“DOR”) proposal in September 2021 to update its regulations. The proposed
