It is unlikely that the first word you think of when you hear the word “apportionment” is “predictable.” Most likely it is “equitable” (AKA “fair”), “uniform,” “alternative,” or maybe even a “factor” (“single-” or “three-”). But for corporate tax departments, predictability in income tax apportionment is of enormous value. A company needs to be able
At COST’s annual meeting in San Antonio two weeks ago, I participated on a panel regarding state tax penalties. We focused on a troubling trend: states increasingly using penalties to raise revenue, whether by building them into newly enacted and unusual taxes or by expanding the application of existing penalties. The premise that penalties can
Building on our prior Tax Notes State article that examined the history, purpose and policy rationale behind 80/20 company rules, Partners Jeff Friedman and Ted Friedman, and Associate Stephanie Terinoni, revisit the topic in this installment of “A Pinch of SALT,” taking a closer look at 80/20 companies and challenging several common misconceptions about their
Over the years, I’ve often been asked how the MTC chooses its meeting locations. Although I can’t speak to how those decisions are made today, I can lift the curtain on how they were made in the recent past, including the choice of Savannah, Georgia, for the MTC’s fall meetings this November.
The MTC must
The IRS developed the Modernized e-File (MeF) system in the early 2000s and first deployed it in 2004. MeF is an Internet-based system that allows taxpayers to electronically file corporate, individual, partnership, exempt-organization, and excise tax returns. Working with the Federation of Tax Administrators and 28 state tax agencies, the IRS expanded MeF in 2006
At TEI’s 2026 Audits & Appeals Seminar earlier this week, I learned something astonishing. During a discussion of managing audits and controversies, the audience was asked how many participants typically meet with a state auditor at the outset of an audit. Very few hands went up. One audience member estimated that such meetings occur only
The so-called black box problem describes the difficulty of understanding how a complex system reached a conclusion, even when all the inputs are known. More than a decade into the age of modern artificial intelligence and several years into the public availability of generative AI, that problem is more prevalent and more consequential – particularly
New York’s new sales tax vendor re-registration program includes a potentially valuable penalty and interest discount program for eligible vendors. However, qualifying for the program may be more complicated than it first appears, particularly for taxpayers with unresolved controversies or liabilities that are not yet fixed and final.
In this installment of NY Tax Talk
State tax audits are not just compliance exercises; they are the point at which a state’s stated audit purpose, the auditor’s actual focus, and the taxpayer’s practical obligations meet. Every state’s audit process is aimed, ultimately, at determining whether a taxpayer reported and paid the correct amount of tax. States describe that purpose in different
