Shaking things up in state and local tax
Shaking things up in state and local tax
How do you change your state of domicile? What makes you a resident of a particular state? While these questions appear simple on the surface, the answers are complex and can vary depending on the state. Eversheds Sutherland’s SALT team has honed our knowledge and expertise on these issues to provide answers....Read More
By Stephen Burroughs and Pilar Mata
The California Franchise Tax Board (FTB) issued a legal ruling determining that it will attribute the business activities of a multiple-member limited liability company classified as a partnership for tax purposes (LLC) to its members when determining whether such members are “doing business” in California. As a result…
The New York State Governor and Legislature recently enacted the 2014-2015 New York State Budget, Senate Bill 6359-D and Assembly Bill 8559-D (Budget), which results in the most significant overhaul of New York’s franchise tax on corporations in decades. In this edition of New York Tax Reform Made Easy, we will address the changes made to apportionment sourcing in computing a taxpayer’s apportionment factor.
Continue Reading New York Tax Reform Made Easy: Apportionment
By Shane Lord and Prentiss Willson
Under the Delaware Infrastructure Emergency Response Act, emergency work related to a declared state of emergency does not constitute legal presence, residency, or doing business in Delaware for purposes of state and local taxes, licensing, and regulatory requirements. This exclusion applies to out-of-state businesses and employees that conduct emergency…
By Scott Booth and Timothy Gustafson
The Massachusetts Appellate Tax Board ruled that an out-of-state corporation’s subsidiary qualified as a financial institution by virtue of the lending activities undertaken by the trusts in which it held beneficial ownership and from which the subsidiary derived more than 50% of its gross income. Under Massachusetts’ statutory “catchall”…
The Virginia Tax Commissioner overturned the Department of Taxation’s adjustments to a taxpayer’s nonresident Virginia income tax return based on a determination that certain transactions between related entities were indeed conducted at arm’s-length, contrary to the Department’s prior findings. The nonresident taxpayer was the majority owner of both an out-of-state LLC as well as a…
