Read our November 2017 posts on stateandlocaltax.com or read each article by clicking on the title. For the latest coverage and commentary on state and local tax developments delivered directly to your phone, download the latest version of the Eversheds Sutherland SALT Shaker app.

• SALT Pet of the Month: Leon
  Meet Leon, the spunky little kitten belonging to Legal Secretary Samantha Duzniak.
• California Declines to Extend Landing-Based Situs Property Tax Rule to All Aircraft
  The California Court of Appeal held that the entire value of an air taxi company’s jets were subject to the County of Los Angeles 1% personal property tax, despite the fact that the jets spent 40% of their time outside of California.
• Colorado Court of Appeals Held that Out-of-State Holding Company is Not Included in Combined Report
  The Colorado Court of Appeals held that a corporate parent doing business in Colorado was not required to include its subsidiary holding company that held no property or payroll in Colorado or elsewhere in its Colorado unitary combined corporate income tax report.
• Watch Your Step: New York City Real Property Transfer Tax Imposed Under Step Transaction Doctrine
  The New York State Supreme Court, Appellate Division, affirmed the New York City Tax Appeals Tribunal’s (Tribunal) determination that certain real estate transactions were subject to the New York City Real Property Transfer Tax (RPTT) under the step transaction doctrine.
• New York State Advisory Opinion: Non-US Unauthorized Life Insurance Companies’ Premiums Excluded from Apportionment Factor
  The New York State Department of Taxation and Finance issued an advisory opinion determining that non-US unauthorized life insurance companies’ premiums were not includable in the New York State insurance franchise tax apportionment factor.
• New York State Appellate Division Affirms that HMOs Were Subject to New York City General Corporation Tax
  The New York State Supreme Court, Appellate Division, affirmed the New York City Tax Appeals Tribunal’s (Tribunal) decision that Aetna’s subsidiary health maintenance organizations (HMOs) were subject to the New York City General Corporation Tax (GCT) for 2005 and 2006.
• Washington Strikes and Hits Again – Nonresident Jeweler Subject to Washington B&O Tax
  The Washington Administrative Review and Hearings Division of the Department of Revenue found that an out-of-state diamond and gold wholesaler was subject to the business and occupation (B&O) tax based on in-state consigned property.
• Tax Reform Executive Summary – A 2-Pager on the 7 Things You Need to Know
  Tax reform efforts, if successful, will have a major impact on virtually every business. There has been a great deal of reporting on the tax reform process and the proposed changes to the US Internal Revenue Code (IRC).
• The State and Local Tax Implications of Federal Tax Reform
  On November 2, 2017, Republicans in the House of Representatives released their much-anticipated tax reform bill. The Tax Cuts and Jobs Act proposes numerous changes to the Internal Revenue Code, many of which will have an impact on taxpayers’ state and local tax liabilities.

ANNOUNCEMENTS

• 2017-2018 Maryland State Bar Association State Tax Study Group
  The Maryland State Bar Association (MSBA) Taxation Section works to further the mutual interest of MSBA members concerned with the law relating to taxes through stimulating the interest of MSBA members and informing them in the law concerning Maryland and Federal taxation; studying proposed improvements and reforms in such laws through legislation and otherwise; and generally promoting the interests and welfare of Bar members and the public in the areas of taxation. Throughout 2017 and 2018, Eversheds Sutherland SALT will host a live videocast of the MSBA State Tax Study Group’s meetings on the third Tuesday of a month from 8:30 – 9:30 a.m. Eastern in our Washington, DC office (700 Sixth Street, NW, Suite 700, Washington, DC).

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