The New York Division of Tax Appeals (DTA) held that a taxpayer’s employment severance payment received over a year after her relocation out of the state was allocable to New York for personal income tax purposes.
The taxpayer worked for a school in New York for 11 years before going on sabbatical leave and moving
The New York State Division of Tax Appeals determined that income from the vesting of restricted stock units of a nonresident taxpayer were subject to New York State personal income tax based on the taxpayer’s performance of services in New York during the restricted stock units’ vesting period. The Tribunal also determined that dividends on
Last year, the Texas Comptroller proposed a regulation that affects how local sales tax is allocated for online sales, to become effective October 1, 2021. While Texas generally uses origin-based sourcing, under the new rule, online sales will generally be sourced to the destination of the sale. Local governments protested these amendments, arguing that
On Friday, June 4, 2021 at 10:00 a.m. PST, the California Franchise Tax Board (“FTB”) will hold its sixth interested parties meeting (“IPM”) to discuss its latest proposed amendments to the market-based sourcing regulation, Cal. Code Regs., Title 18, Section 25136-2. At the IPM, FTB will discuss and solicit public input on the newly-proposed regulation
The Illinois Department of Revenue issued a private letter ruling determining that for purposes of the Retailers’ Occupation Tax (ROT) and the Services Occupation Tax (SOT), a taxpayer that procured marketing materials on behalf of its clients properly sourced these sales to the location of the product manager, the employee responsible for procuring the materials.
The Pennsylvania Commonwealth Court issued its much-anticipated decision on July 24 in Synthes USA HQ Inc. v. Commonwealth of Pennsylvania.
The Washington Court of Appeals held that taxpayer’s receipts for referral services are sourced to Washington for B&O tax purposes to the extent that such receipts are received from a lender located in Washington. The taxpayer operates an online platform through which the taxpayer offers educational tools on the loan process to prospective borrowers, analyzes
States have enacted new marketplace facilitator laws designed to impose sales tax obligations on marketplace facilitators related to sales made by third-party sellers. These new sales tax collection obligations on marketplace facilitators create the potential for class-action lawsuits arising out of unintended overcollection of tax.
Today’s Marketplace Monday explores two legislative solutions to overcoming this
By Chris Lutz and Andrew Appleby
In Georgia Letter Ruling SUT-2016-24, the Georgia Department of Revenue ruled that sales of software equipment delivered to a Georgia assembly facility on an out-of-state customer’s behalf were subject to Georgia sales and use tax. In the ruling, the taxpayer sold technology solutions, which were comprised of licenses of
On January 5, 2017, a New York State Division of Tax Appeals administrative law judge (ALJ) determined that a taxpayer’s electronic bill payment and presentation receipts constitute “service” receipts and not “other business receipts,” and are properly sourced where the service is performed. In the Matter of the Petitions of Checkfree Services Corp.
