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The New York State Governor and Legislature recently enacted the 2014-2015 New York State Budget, Senate Bill 6359-D and Assembly Bill 8559-D (Budget), which results in the most significant overhaul of New York’s franchise tax on corporations in decades. In this edition of New York Tax Reform Made Easy, we will address how the Budget modifies the income tax base and changes various tax rates.
Continue Reading New York Tax Reform Made Easy: Business Income Base and Tax Rate

By Sahang-Hee Hahn and Timothy Gustafson

The Indiana Department of Revenue required an out-of-state clothing company and its subsidiary to file a combined Indiana corporate income tax return, determining that the taxpayer’s transfer pricing study was insufficient to establish that its intercompany transactions were conducted at arm’s length. The taxpayer was the parent of a…

The New York State Governor and Legislature recently enacted the 2014-2015 New York State Budget, Senate Bill 6359-D and Assembly Bill 8559-D (Budget), which results in the most significant overhaul of New York’s franchise tax on corporations in decades. In this edition of New York Tax Reform Made Easy, we will address how the Budget implements unitary combined reporting and expands the use of economic presence nexus.
Continue Reading New York Tax Reform Made Easy: Unitary Combined Reporting and Nexus

The Sutherland SALT Team will release commentary on the revamped New York State corporate tax system that was reformed as part of the recently enacted Budget Legislation (“Budget”). By way of background, Governor Andrew Cuomo signed into law the tax provisions of the Budget on March 31. The changes will affect nearly every New York…

By Ted Friedman and Prentiss Willson

The Indiana Department of Revenue determined that affiliated entities of an out-of-state manufacturing corporation were not unitary. The corporation conducted marketing operations as one business segment and production operations as a second business segment. The corporation included its marketing entities in its Indiana consolidated return. On audit, Department staff…

By Stephanie Do and Andrew Appleby

The Indiana Department of Revenue determined that an out-of-state wireless communications equipment wholesaler’s in-state business activities were protected by P.L. 86-272, and therefore, the wholesaler did not have nexus for Indiana corporate income tax purposes. The wholesaler’s in-state activities were limited to shipping products to Indiana customers by common…

By Madison Barnett and Andrew Appleby

The Florida Department of Revenue determined that a company providing television viewing data and analytics services must source its receipts from such services to the location of its customers, despite (1) the state’s majority costs of performance souring rule and (2) that the taxpayer appeared to incur the majority…

Today, the Maryland Court of Appeals held that Maryland may tax out-of-state Delaware holding companies that license patents to their parent company, which was doing business in Maryland. Gore Enterprise Holdings, Inc. v. Comptroller of the Treasury and Future Value, Inc. v. Comptroller of the Treasury. The ramifications of this decision are significant because…

By Suzanne Palms and Pilar Mata

The Florida Department of Revenue determined that sufficient reasonable cause had been established to allow a taxpayer to discontinue filing a consolidated Florida corporate income tax return because the taxpayer had experienced “substantial growth.” The Department noted that the taxpayer’s employees, assets and income had increased, and the taxpayer…