By Jessica Allen and Jonathan Feldman
The New York City Tax Appeals Tribunal administrative law judge (ALJ) determined that a taxpayer’s receipts for consulting services should be allocated based on where the services were rendered, not where the solicitation and payment for the services occurred. The taxpayer’s non-commissioned salespeople entered into lump-sum subscription agreements with
By Elizabeth Cha and Timothy Gustafson
On October 26, 2016, the South Carolina Court of Appeals reversed a lower court ruling and determined the Department of Revenue (Department) failed to satisfy its burden of showing that the statutory apportionment formula did not fairly represent Rent-A-Center West Inc.’s (RAC) business activities in South Carolina. This case
By Douglas Upton and Andrew Appleby
The New Jersey Tax Court determined that credit card issuers must source to New Jersey all of their interest and interchange fee receipts, and half of their credit card service fees, from New Jersey accountholders. The Tax Court concluded that the Division of Taxation’s regulations required the taxpayers to
By Zachary Atkins and Open Weaver Banks
The New Jersey Tax Court held that apportioning all of a company’s income to New Jersey for corporate business tax purposes, even with the allowance of a credit for taxes paid to separate-return states, failed to fairly reflect the company’s business activities in New Jersey. The court also
By Charles Capouet and Maria Todorova
The Franklin County Circuit Court held that Netflix’s subscription-based streaming video service was not subject to Kentucky’s gross revenues tax, excise tax and school tax (telecommunications taxes) imposed on “multichannel video programming service” (MVPS). Under Kentucky law, MVPS is programming “provided by or generally considered comparable to programming provided
We are pleased to announce that our SALT practice has expanded with the recent addition of five associates: Jessica N. Allen in Sacramento, Chelsea E. Marmor and Douglas J. Upton in New York, DeAndre R. Morrow in Washington DC and Alla Raykin in Atlanta.
The group’s arrival to Sutherland’s more than 100-strong tax practice brings
For the second year, Sutherland Asbill & Brennan LLP is delighted to join TEI’s Audit & Appeals Seminar, sponsor, and lead a full day dedicated to state and local tax controversies covering:
Sutherland is pleased to announce that Partner Carley A. Roberts has been recognized as one of the “Outstanding Women in Tax” by Tax Analysts, a leading publisher of tax news and analysis.
A group of Tax Analysts editors, reporters and board members reviewed more than 300 submissions, of which only 10 women were honored for
Sutherland SALT has launched the “SALT Scoreboard,” a quarterly publication that tracks significant state tax litigation and controversy developments and tallies the results of taxpayer wins and losses across the country. Our quarterly publication will feature Sutherland’s observations regarding important state tax decisions and will identify trends by issue, state and forum as they emerge
Sutherland SALT is shaking things up again in state and local tax. We are pleased to announce several new enhancements to our SALT Shaker app. These improvements give users more options to customize and search content, making it even easier to be one step ahead with the latest coverage and commentary on state and local
