Archive for July 2017
Contracting with Third-Party Fulfillment Centers in Virginia Creates Nexus for Sales Tax
As the retail industry continues to evolve in the online marketplace, many smaller companies are using third-party fulfillment networks to store their…
Read MoreThe Watts Brothers’ Lightbulb Moment: Why You Should Involve Your CPA Early on in the Transaction Process
https://whatsnext.aprio.com/watts-brothers-lightbulb-moment-involve-cpa-early-transaction-process/
Read MoreInternal Use Software – Determining Which Accounting Guidance to Use
In the last decade, the cloud computing industry has grown exponentially. Software-as-a-service (SaaS) platforms are currently dominating the industry, and internal use software offerings and methods of delivery are continuously evolving. Despite these sweeping changes, accounting guidance has had no major changes. As a result, people are often confused on how to account for the…
Read MoreAccounting for Development Costs of Internal Use Software
Internal use software is software that is acquired or internally developed to meet an entity’s internal needs. These internal needs include, but are not limited to, software that is only used internally, such as payroll systems and CRM tools, and cloud-based SaaS products that the entity’s customers are provided with hosted access for a period…
Read MoreNew Jersey Rules that Intercompany Royalty Expense is Deductible
Intercompany agreements are common among groups of related entities, and they can involve (i) the provision of services from one entity to another, (ii)…
Read MoreCalifornia Court Holds that Transfers of Interests in Entities Owning Real Property Can Result in Transfer Taxes
In California, counties and cities may apply a transfer tax on a deed, instrument or writing by which a real property interest is transferred for consideration – including the transfer of an ownership interest in a legal entity that owns real property. Real estate transfer taxes (RETT) are regularly applied by states and their subdivisions…
Read MoreWashington Rules that Dentist Owes Use Tax Based on Purchase Price, Not Value
In a recent Washington case, the taxpayer owed use tax based on the value he paid for the property; the fact that he made a “bad bargain” did not constitute grounds for reducing the use tax owed. By Jeff Glickman, SALT partner Use tax continues to be one of the most confusing, and most often…
Read MoreIowa Rules that Parent is not Includable in Consolidated Group and Subsidiaries Can’t Deduct Interest
In a case highlighting the issues that often affect consolidated/affiliated groups, a state income tax inefficiency was created when a consolidated group was sold and the parent financed the former owner’s stock redemption. By Jess Johannesen, SALT manager On May 3, 2017, the Iowa Court of Appeals issued a decision in which it held that…
Read MoreU.S. Tax Court Rules Disposition of U.S. Partnership Interest by Foreign Partner is Not U.S. Source Income
By Philip Brudney, manager, and Ethan Deng, senior tax associate A new Tax Court decision marks a major shift in the tax consequences of the disposition of a U.S. partnership interest by a foreign partner. Until now, the disposition of a U.S. partnership interest by a foreign partner was governed by IRS Revenue Ruling 91-32.…
Read MoreBishop Estate Trust Case Study: Avoiding Conflicts of Interest
Most people involved with nonprofit organizations are familiar with the concept of “conflicts of interest.” Generally, nonprofit board members should have a high standard of care and undivided loyalty to the nonprofits they serve. There should be no instances of self-dealing for themselves, people, or businesses related to them. For example, if a nonprofit is…
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