The November 26, 2018, release by the Internal Revenue Service of proposed regulations (REG-106089-18) related to IRC § 163(j) has provided some clarity for federal income taxpayers. But the regulations’ treatment of federal consolidated groups gives rise to complexities and questions as to how the limitation will operate at the state level.
This Bottom Line videocast includes:
The November 26, 2018, release by the Internal Revenue Service of proposed regulations (REG-106089-18) related to IRC § 163(j) has provided some clarity for federal income taxpayers. But the regulations’ treatment of federal consolidated groups gives rise to complexities and questions as to how the limitation will operate at the state level. In this Bottom Line videocast Eversheds Sutherland attorneys Todd Betor and Elizabeth Cha discuss:
The US Supreme Court recently overruled the long-standing “physical presence rule” that barred states from imposing sales tax collection requirements on certain out-of-state sellers. However, in South Dakota v. Wayfair, Inc., the Court did not clearly state a new standard to replace the physical presence rule. States are responding to the decision in different ways. This Bottom Line videocast, Eversheds Sutherland attorneys Todd Lard and Jessica Eisenmenger discuss:
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. In this Bottom Line videocast, Eversheds Sutherland attorneys Charles C. Capouet and Justin B. Stone discuss the results from the first two quarters of 2018, including:
In this Bottom Line videocast, Eversheds Sutherland attorneys Aaron Payne and Todd Betor discuss the state tax consequences and considerations of IRC § 965. This videocast includes:
Consumption-based taxes are spreading worldwide, and multinational businesses need to be aware of the global indirect tax landscape. Governments are looking for ways to react to and manage the disruptive effect of new and emerging business models, and they are using technology to collect, analyze and share taxpayer data.
In the new Bottom Line videocast, Eversheds Sutherland (US) Partner Maria Todorova and Eversheds Sutherland (International) Partner Giles Salmond discuss:
The state and local tax (SALT) implications of federal tax reform are numerous, yet still often unclear. With states releasing new law and guidance about federal tax reform, taxpayers must stay abreast of this very dynamic area of law. In this videocast, Todd Lard and Todd Betor discuss the gating question to the SALT implications of federal tax reform—state conformity to the IRC—along with other SALT considerations pertaining to major general, domestic and international tax provisions included in the new tax law.
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. In this videocast, Charles C. Capouet and Jessica N. Allen share 2017 year-end observations, including taxpayers’ performances in corporate income tax and sales and use tax cases and the Pennsylvania Supreme Court’s decision in Nextel. Stay tuned for upcoming 2018 editions of the Eversheds Sutherland SALT Scoreboard!
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. In this videocast, Charles C. Capouet and Hanish S. Patel share the second quarter highlights from the SALT Scoreboard, including a breakdown of corporate income tax and sales and use tax case results, an overview of the most significant cases of the quarter, and a recap of the Maine Supreme Judicial Court’s holding in State Tax Assessor v. MCI Communications Services, Inc. Stay tuned for our Eversheds Sutherland SALT Scoreboard 2017 Year in Review!
