In this episode of the SALT Shaker Podcast, host Chris Lee discusses a California income tax matter concerning the sourcing of an individual’s income, a Wisconsin corporate income tax matter involving the dividends received deduction, and two Idaho individual income tax decisions addressing domicile.
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It goes without saying that an individual is free to move about the country and to change their state of residency/domicile for state income tax purposes. However, that change is potentially complex under the law, especially when an individual who is a longtime resident/domiciliary of California plans to become a nonresident.
In this article for
After a successful trial-run, the Illinois Department of Revenue (IDOR) recently announced plans to expand its Audit Fast Track Resolution (FTR) program to general income tax disputes in October.
The FTR program allows for the expedited resolution of audit disputes through a conference with a neutral mediator while a case is still under the jurisdiction
The Mississippi Supreme Court ruled that an affiliated group of telecommunications companies properly computed the Broadband Investment Credit in determining their franchise and income tax liabilities. The Broadband Credit may be used by a taxpayer to offset up to 50% of the taxpayer’s tax liabilities in a given year. The taxpayers filed separate Mississippi franchise
Effective July 1, 2020, Iowa law permits utility companies to utilize an inflow-outflow billing method for eligible distributed generation facilities. Under the inflow-outflow method, a generation customer is responsible for paying for the inflow kWh energy charge (sales to customer), while the amount of outflow kWh energy charge is credited to the customer (purchases from
A recent letter ruling from the Tennessee Department of Revenue concludes that the ownership of mortgages backed by Tennessee property was insufficient to subject a foreign investment fund (“Fund”) to the state’s franchise and excise taxes.
Tennessee broadly applies its franchise and excise tax to the extent permitted by the U.S. and state constitutions. A
On October 7, 2020, the Massachusetts Appeals Court held that a taxpayer’s deduction for payment of the Indiana utility receipts tax (“URT”) was permitted for Massachusetts corporate income tax purposes. The taxpayer who was engaged in natural gas distribution operations in Massachusetts and other states, claimed a deduction for the URT it paid to Indiana
A New York City Administrative Law Judge held that a New Jersey S corporation (“Taxpayer”) was subject to New York City general corporation tax (“GCT”) on gain from the sale of a minority limited partner interest in a limited partnership that leased and managed New York City real estate. The Taxpayer argued that the gain
The Texas Comptroller of Public Accounts issued a private letter ruling concluding that several services provided to optometrists and ophthalmologists were subject to sales tax as data processing. Specifically, the Comptroller determined that the taxpayer’s web-based software system, which doctors use to manage patient relationships, schedule appointments, refill prescriptions, and communicate about treatment, is a
The New Jersey Superior Court reversed the New Jersey Tax Court and held that an individual taxpayer was permitted to carry forward losses from a partnership incurred in 2009 to reduce the individual’s distributive share of the partnership’s income in 2010. The Court explained that, pursuant to IRC § 465, a partner in a partnership
