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The Tax Cuts and Jobs Act (TCJA), P.L. 115-97, limited itemizers' state and local tax (SALT) deductions to $10,000 for tax years 2018 through 2025 (the SALT cap). However, federal [...]

I. Introduction This issue of SALT Block reviews four recent state supreme court decisions interpreting state tax law provisions. The focus of the column is that the meaning of tax [...]

I. Introduction This issue of SALT Block reviews three recent state supreme court decisions relating to the limitations imposed on state and local governments to tax by the Supremacy Clause, [...]

Many tax professionals have faced a residency issue with respect to state taxation. The U.S. Citizenship and Immigration Service (USCIS) grants approximately 1 million Green Cards and employee visas annually; [...]

I. Introduction This issue of SALT Block reviews two recent state supreme court decisions relating to the limitations imposed on state and local governments to tax by the Commerce Clause [...]

California began as a Joyce state, changed to a Finnigan state, reverted back to a Joyce state, and then back again to being a Finnigan state. If you find that [...]

I. Introduction One of the nagging problems in state corporate taxation is whether gross receipts should be excluded from the sales factor in the apportionment formula. Taxpayers often want to [...]

Introduction On December 14, 2023, the San Francisco Superior Court granted the American Catalog Mailers Association's (the "ACMA") motion for summary judgment and struck down P.L. 86-272 "guidance" issued by [...]

Prior to the 1957 adoption of the Uniform Division of Income for Tax Purposes Act's (UDITPA's) three-factor apportionment formula, many states had apportioned taxable income based on a single-factor apportionment [...]

To respond to rapidly changing state and local tax (SALT) developments, this article envisions how a well-balanced SALT team can serve the needs of a large multistate business. It is [...]

Since the compromise at the League of Nations in 1928, the international income tax concept of "nexus," under which a jurisdiction may claim the right to tax income, has enjoyed [...]

With the passage in recent years of significant federal tax legislation, there has been considerable discussion among state tax practitioners about how federal tax changes affect or could affect taxpayers [...]

In an informative session on the first day of the 75th Anniversary Celebration and Annual Conference in October, experts addressed the topic "SALT Tax Policy: As Deficits Turn, Will the [...]

Registering for sales taxes is the first step a company takes to inform a state that it operates within the state's jurisdiction and is accountable for collecting and remitting sales [...]

Despite the lack of a direct and/or indirect physical presence in the state, economic nexus exists for an out-of-state enterprise by deriving income from sources within the state as a [...]

Introduction and History "Bundled transaction." Bundled transaction? What a complicated mess! As the law around "bundled transactions" has evolved, sometimes in ways that are not entirely consistent, one thing is [...]

Overview The taxation of maintenance contracts varies widely from state to state, although an increasing number of states are imposing tax on selected services, including maintenance contracts. As states search [...]

Homeownership is a fundamental part of the American dream. Despite recent economic challenges, the wish to own a home remains strong. But according to a recent survey by Bankrate, while [...]

2023 has been a relatively quiet year from both a tax standpoint, and an overall economic standpoint, for the United States. After 2022 saw historically high inflation as the economy [...]

Florida Apportionment Rules Florida requires corporations to apportion income using a three-factor property, payroll, and sales apportionment formula that double-weights the sales factor. (1) The term "sales" means all gross [...]

Americans are continuing to pack their bags, fleeing high-cost-of-living areas and relocating to states with more favorable tax climates. This migration trend, influenced by a combination of economic and lifestyle [...]

I. Introduction Limitations on the power of state and local governments to impose taxes are a constant theme in the state and local tax arena. This issue of SALT Block [...]

The Supreme Court's decision in South Dakota v. Wayfair, Inc. is now over five years old. In Wayfair, the Supreme Court overruled the Commerce Clause "physical presence" requirement for state [...]

Dante tells us that inscribed on the gates of Hell are the words, "Abandon all hope, ye who enter here." The same sentiment is appropriate for anyone trying to determine [...]

Introduction--Shifting Preferences The nature of work is changing. The increased popularity of remote employment has effectively enabled the U.S. workforce to reside in the states they so desire, as opposed [...]

Along with other tax policy and advocacy organizations, the AICPA has been developing and providing resources to state CPA societies interested in encouraging states and their tax authorities to make [...]

In This Department CREDITS AGAINST TAX Credit for increasing research activities in a short tax year; p. 7. New advanced energy project tax credits under the Inflation Reduction Act; p. [...]

I. Introduction This issue of SALT Block reviews several recent state supreme court rulings in state and local taxation. These include decisions arising as repercussions of coronavirus disease ("COVID") (Washington [...]

Introduction The state and local tax deduction, also referred to as the "SALT deduction," allows taxpayers to deduct certain state and local taxes from their federal income tax returns. (1) [...]

With more than $15 trillion in annual household spending, per the World Bank, the United States is an attractive market for non-U.S. corporations. Globalization, technological advancements, and multinational trade agreements [...]

Accounting for income taxes in accordance with FASB Accounting Standards Codification (ASC) Topic 740, Income Taxes, is a time-consuming and complex process. Federal and state tax laws are constantly changing [...]

March 1, 2024 RELATED March 1, 2024 Current developments in taxation of individuals March 1, 2024 Sec. 1402(a)(13) and limited partnerships February 17, 2024 On Form 1099-K delays, Werfel says [...]

State conformity to the federal Internal Revenue Code is not a new topic, but it continues to challenge states and taxpayers whenever Congress amends the Code. This item aims to [...]

The division of multistate business income among the states is accomplished through formulary apportionment. State formulary apportionment provisions increasingly rely on the receipts factor to divide income, sharpening the focus [...]

I. Introduction This issue of SALT Block reviews several recent state Supreme Court ruling in the area of state and local taxation. These include decisions relating to the retroactive application [...]

If you have never had the privilege of working through a sales and use tax audit, particularly local audits, now is your chance to stop reading. However, for those who [...]

On May 11, 2023, the U.S. Supreme Court held (1) that the National Pork Producers' position, regarding California restrictions on pork sold within the state, did not state a claim [...]

February 1, 2024 Recent changes to the treatment of research and experimental (R&E) expenditures for federal income tax purposes beginning with the 2022 tax year are having a significant impact [...]

For the 2022 tax year, of the forty-five states (plus the District of Columbia) that impose a corporate income tax, more than thirty require the use of a single sales [...]

The law known as the Tax Cuts and Jobs Act (TCJA) of 2017, P.L. 115-97, included some major changes to the Code, but not all of them are here to [...]

Law firms periodically receive requests for advice from CPAs regarding a client's need to come into compliance with the relatively new and sometimes confusing "economic nexus" or "Wayfair" rules for [...]

I. Income and Franchise Taxes--Nexus The Massachusetts Supreme Judicial Court ("SJC") ruled in favor of a company and held that it had not established nexus with the state based on [...]

Historically, Florida has earned a reputation as one of the most taxpayer-friendly states for businesses. In fact, Florida Governor Ron DeSantis recently announced his budget proposal for the 20242025 fiscal [...]