income tax

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The Idaho State Tax Commission found an individual taxpayer remained domiciled in the state and thus liable for Idaho individual income taxes where there was no evidence he ever abandoned his Idaho domicile. The taxpayer was audited and issued a notice of deficiency determination because the taxpayer did not file a tax return in Idaho…

The Virginia Department of Taxation issued a private letter ruling on May 25, 2021, determining that a man who relocated out of Virginia as a result of a new position with his employer, but retained his Virginia driver’s license and motor vehicle registration in order to facilitate a potential return to the state in the…

The Virginia Department of Taxation recently released Letter Ruling 21-59 (dated May 18, 2021), determining that Virginia-sourced wage income earned by a wife under federal nonresident alien status was taxable to a couple with part-time Virginia residency.

The couple began residing in Virginia in June 2017 and spent 199 days in the state that year. …

On May 18, the California Office of Tax Appeals (“OTA”) issued a pending precedential decision holding that community income derived from nonqualified stock options (“NQSOs”) and restricted stock units (“RSUs”) granted to a resident in exchange for services performed exclusively in California and vested while a California resident is taxable California source income to a…

On May 27, the New Jersey Tax Court held that the New Jersey Division of Taxation could not eliminate a taxpayer’s net operating losses generated during years beyond the statute of limitations. The division’s proposed reduction was based on a transfer pricing adjustment between related entities for years never audited by the division and otherwise…

South Carolina’s Department of Revenue (DOR) recently published the inaugural edition of its Guide to Determining a Taxpayer’s Domicile for Income Tax Purposes (Guide). The publication issued by the DOR’s Policy Division provides a general overview of South Carolina’s domicile rules for income tax purposes. The intent of the guide is to assist taxpayers and…

Louisiana codified an individual income tax exemption for “digital nomads.” SB 31 (Effective Jan. 1, 2022). “Digital nomads” are defined as individuals who establish residency in Louisiana after December 31, 2021, have health coverage, and work remotely, full-time for a nonresident business. The exemption applies to 50% of the digital nomad’s gross wages, not to…

On May 17, 2021, the New York Tax Appeals Tribunal (Tribunal) held that when determining whether a New York C corporation must mandatorily elect to be treated as an S corporation as a result of the investment ratio test provided by New York Tax Law § 660(i), such test requires that “federal gross income” adopt…

On April 14, 2021, the Oregon Tax Court issued a ruling on cross motions for summary judgment in a case involving the inclusion of receipts from commodity hedging activities in the taxpayer’s sales apportionment factor. Chevron filed amended Oregon corporation excise tax returns including its gross hedging receipts in its Oregon sales apportionment factor, and…