The Nebraska Supreme Court upheld a lower court decision that a couple, partial owners of large trucking company, failed to prove that they changed their domicile from Nebraska to Florida for income tax purposes from 2010 to 2014. The taxpayers argued that they had changed their domicile to Florida, asserting that they had acquired a
Taxability Partnerships/Pass-through
Workaround this: No income tax credit for Maine taxpayer who paid Connecticut pass-through entity tax
By Timothy Gustafson & Annie Rothschild on
Posted in Income Tax
The Maine Board of Tax Appeals (Board) disallowed a resident individual taxpayer’s claim for a Maine income tax credit for taxes paid to Connecticut by the taxpayer’s limited liability company (the Company). The Company, treated as an S corporation for federal purposes, paid Connecticut’s entity-level tax on pass-through entities (a tax that operates as a…
Swart Distinguished: Foreign LLC Doing Business in California by Virtue of its 50% Interest in Pass-through Entity
By Todd Betor & Eversheds Sutherland SALT on
The California Office of Tax Appeals (OTA) found that a foreign single-member LLC domiciled in Georgia was “doing business” in California by reason of its 50 percent interest in a pass-through LLC operating in California (LLC) and thus, was subject to the state’s annual LLC tax. The OTA focused on California’s definition of “doing business”…