Sutherland and the Tax Executives Institute (TEI) are pleased to present this first ever full-day program dedicated to the “Theory, Strategy and Practice of State Tax Controversy” in San Francisco, California on May 21. Topics covered will include:
Continue Reading Join Sutherland and TEI for a full day SALT controversy workshop at the 2015 Audits and Appeals Seminar in San Francisco (May 19-21, 2015)
corporation business tax
Not Another Add Back: New Jersey Tax Court Again Rules Add Back of Certain Taxes Not Required
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Posted in Noteworthy Cases
By Ted Friedman and Andrew Appleby
The New Jersey Tax Court held that a corporation was not required to add back electric utilities taxes paid to North Carolina and South Carolina to determine the corporation’s entire net income subject to the New Jersey Corporation Business Tax (CBT). The Tax Court concluded that the electric utilities…
New Jersey Supreme Court Delivers Good News to Taxpayers in UPS Case
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By Nicole Boutros and Andrew Appleby
The New Jersey Supreme Court held that the New Jersey Division of Taxation improperly exercised its discretion when it refused to waive its imposition of $1.8 million in late payment penalties and tax amnesty penalties. The taxpayers, five subsidiaries of United Parcel Service of America (collectively, UPS), used a…
Has New York City Added a Fourth Element for Determining a Combined Group?
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Posted in New York, Noteworthy Cases
A New York Tax Appeals Tribunal Administrative Law Judge (ALJ) recently determined that a federal savings and loan association was not required to include a subsidiary, which was formed as a Connecticut passive investment company, in its combined New York City bank tax return. In the Matter of the Petition of Astoria Financial Corporation &…
Connecticut “WREITS” Guidance for REITs and Economic Nexus
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Recently, the Connecticut Department of Revenue Services issued an informational publication explaining its position on the application of the Connecticut Corporate Business Tax on real estate investment trusts (REITs) and revised a previously issued publication on the implications of the state’s economic nexus provisions to foreign (non-U.S.) companies.
The Department’s newly issued guidelines treat REITs in a manner that is similar to the Internal Revenue Code, but the Department strays in certain areas. IP 2010(21) (Dec. 1, 2010).Continue Reading Connecticut “WREITS” Guidance for REITs and Economic Nexus