Posted in Corporate Income Tax, Nexus, Property and Other State/Local Tax Issues, SALT Strategies

Market Based Sourcing – No Time To Hibernate

It is always fascinating to watch trends develop and revisit whether the prognosticators were correct – we even enlist Punxsutawney Phil at this time of year – more on him later. One trend we’ve been watching has been the state tax authorities’ modifications in the sourcing of revenue in order to increase the receipts from…

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Posted in Corporate Income Tax, Property and Other State/Local Tax Issues, SALT Strategies

Got Unpaid State and Local Tax Liabilities? Voluntary Disclosure May Be Your “Get out of Jail Free” Card

Voluntary disclosure is not exactly a “get out of jail free” card when it comes to unpaid taxes, but it may be the next best thing. Voluntary disclosure programs allow taxpayers with unreported tax liabilities to come forward and settle their tax liabilities, usually under very favorable terms and frequently avoiding any type of penalty.…

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Posted in Nexus, Personal Income Tax, Property and Other State/Local Tax Issues, SALT Strategies

There’s No “Hot Stove” Off Season for Multistate Taxpayers

What used to be called the “off-season” in  Major League Baseball, now enthusiastically referred to as the “Hot Stove”  offers fans some of the most interesting and potentially impactful activity related to the sport.  To a baseball fan there is no longer an “off-season.” And as we all have experienced,…

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Posted in Corporate Income Tax, Income and Franchise, Property and Other State/Local Tax Issues, Sales and Use Tax, SALT Strategies

Fall Clean Up – SALT Considerations When Merging or Liquidating Entities – Beware of Hidden State Tax Dangers in Those Leaves

Wow, October is almost gone! One of my favorite but perhaps most frustrating chores this month is raking the leaves. There are several huge Pin Oaks around my home that provide great shade in the summer and a blanket of leaves in the fall. I always rake the leaves into one or two huge piles…

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Posted in Corporate Income Tax, Nexus, SALT Strategies

Fall Clean Up – SALT Considerations When Merging or Liquidating Entities – Take Time To Step Back To See The Potential

Here in the Northeast, this Fall season has been filled with tranquil weather that invites us to get out for that last round of golf, long bike ride or outdoor exercise without being concerned about bundling up. However, Northeasterners know that this Fall’s tranquility should not lull anyone into complacency about how demanding the…

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Posted in Nexus, Personal Income Tax, Property and Other State/Local Tax Issues, SALT Strategies

Tax Havens – “Water’s Edge” Combined Reporting is Moving Further Abroad

The initial principle of “Water’s Edge” combined reporting was to require combined reporting for affiliated domestic companies that are engaged in a unitary business. Some states have added foreign companies to the Water’s Edge group. These are companies that have a limited United States presence (20% or more) as long as they are part…

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