Following New York City’s recent victory in a case regarding the apportionment of income earned by an out-of-state corporation from its sale of a non-unitary investment, the New York State Department of Taxation and Finance (NYS Department) memorialized the litigation position in an August 4, 2022 revision to the “final draft” regulations that it had

The Multistate Tax Commission (MTC) held its 55th Annual Meeting in Anchorage, Alaska from August 1st through the 4th. During the four-day event, the Audit, Litigation and Nexus Committees met on Monday, the Uniformity Committee met all day Tuesday, the Commission held its annual business meeting and seminar on Wednesday, and

On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after January 1, 2015. The third set of draft regulations relate to apportionment, and contain revisions to the

During the 2022 legislative session, the Georgia General Assembly passed significant tax legislation, including authorizing affiliated groups to file consolidated corporate income tax returns without prior approval from the Department of Revenue, extending and amending qualification for the high-technology and data center sales tax exemptions, extending and increasing several income tax credits, and changing procedures

On January 18, 2022, New York Governor Kathy Hochul released her fiscal year 2023 budget and accompanying legislation (the Budget Bill).  The Briefing Book accompanying the Budget Bill highlights New York’s “remarkable reversal of fortune as tax revenues rebound”—giving the Governor the room to propose a variety of tax cuts targeted toward the middle-class and

In General Motors Corporation v. Commonwealth, the Pennsylvania Supreme Court held that the state’s prior flat $2 million cap on a corporate taxpayer’s net operating loss (NOL) deduction violated the state constitution’s Uniformity Clause and, therefore, the state’s NOL deduction statute must be stricken in its entirety.1 Nevertheless, the Court determined that the

Last week, the Multistate Tax Commission (MTC) held its Fall Executive Committee and Uniformity Committee Meetings (in person) in Alexandria, Virginia. During the Executive Committee Meeting, MTC staff approved California’s participation as a sovereignty member. The Uniformity Committee Meeting focused on discussing the status of its current projects, held its state roundtable, and proposed a

The Louisiana Department of Revenue (the Department) issued Revenue Information Bulletin No. 21-029 (the Bulletin), inviting corporate income taxpayers to resolve intercompany transfer pricing issues via the Louisiana Transfer Pricing Managed Audit Program (the Program) beginning on November 1, 2021. The purpose of the Program is to “create an efficient and expedited resolution for corporate