By Robert P. Merten III and Prentiss Willson
Massachusetts has published its final revised market-sourcing regulation (830 CMR 63.38.1), effective for tax years beginning on or after January 1, 2014. The final revisions to these rules, among other things, conform the regulation with recent state law amendments requiring taxpayers to use market-based sourcing
By Stephen Burroughs and Andrew Appleby
The Alabama Court of Civil Appeals ruled in favor of an out-of-state life insurance company regarding the calculation of its Alabama net worth tax – the Business Privilege Tax (BPT). The BPT requires an insurance company to calculate its Alabama net worth based on the ratio its Alabama premium
By Open Weaver Banks and Pilar Mata
The Indiana Department of Revenue ruled that a limited liability corporation (LLC) that elected to be taxed as a corporation was entitled to use net operating loss (NOL) deductions generated by its former members. The NOLs in question were generated in tax years 2003, 2005, and 2007 by
By Nicole Boutros and Pilar Mata
The Illinois Cook County Circuit Court held that an Illinois law firm (the Relator) that filed a qui tam lawsuit against a taxpayer failed to meet its burden to prove the taxpayer knowingly failed to collect and remit Illinois use tax, as required under the Illinois False Claims Act.
By Derek Takehara and Andrew Appleby
The Illinois Department of Revenue determined that a wholesale distributor of international telecommunications services could source its long-distance telephone receipts based on its Illinois property factor. The taxpayer, an intermediate international telecommunications carrier, owned and rented equipment in several states, including Illinois. Illinois law provides that a taxpayer must
Sutherland SALT is shaking things up again in state and local tax. We are excited to announce the launch of the Sutherland SALT Shaker mobile app, which alerts users to important state and local tax (SALT) developments and enables users to easily find specific, relevant and timely tax insights. The Sutherland SALT Shaker app is
In this edition of A Pinch of SALT, Jeff Friedman, Pilar Mata and Mary Alexander examine the requirements and ramifications of states’ attempts to apply prospective-only remedies to unconstitutional taxes and explore why Maryland State Comptroller of the Treasury v. Wynne is not an appropriate case for prospective-only relief.
Read “Wynne-ing Isn’t
Before entering into agreements with taxing authorities to extend the statute of limitations, taxpayers should consider the legal implications of these agreements, which often are dictated by the states. In this edition of A Pinch of SALT, Sutherland SALT’s Jonathan Feldman, Kathryn Pittman and Maria Todorova explore issues that taxpayers should consider before entering into
We are pleased to announce that Todd A. Lard will rejoin Sutherland’s Washington, DC office on March 4 as a partner in our State and Local Tax (SALT) Practice. For the past five years, Todd Lard worked at the Council On State Taxation (COST), most recently as its vice president and general counsel. Prior to joining
