Archive for December 2018
Washington Finds that ATM Processor’s Service Revenue Sourced to ATM Location for B&O Tax
For apportionment purposes, applying market-based souring rules to service revenues is complicated because it is based on the facts and circumstances of each transaction. Over the past several years, many states have moved from the cost-of-performance method of apportioning service revenues to the market-based approach. A number of those states have provided specific guidance on…
Read MoreOhio Supreme Court Rules That Resale Exemption Applies to Purchase of Promotional Items
Although promotional items purchased and given away for free are typically not eligible for a resale exemption, there may be limited situations where the resale exemption is applicable. By Jess Johannesen, SALT Manager In our June 2017 SALT Newsletter, we detailed an Ohio Board of Tax Appeals (“BTA”) decision in which the BTA upheld a use…
Read MoreUtah Supreme Court Upholds Taxpayer’s Transfer Pricing in Related-Party Transaction
States may have the authority to adjust related-party payments, but only after determining that the transactions are not at arm’s length under federal transfer pricing principles. Transfer pricing issues don’t just arise in international transactions; they arise across state lines as well. Transfer pricing rules give taxing jurisdictions the ability to claw back transactions with…
Read MoreHow Time-Tracking and Data Analytics Can Help Drive Better Business Decisions
Law firms, accountants, consultants and other professional services businesses have long been accustomed to tracking employee time for billing and payroll purposes. But there’s gold in that time tracking data — more than just what comes from billings. Analysis of that data allows firms to gain insights into productivity, plan for staffing demands, improve operations,…
Read MoreQBI Deduction: The Impact of Proposed Regulations on Government Contractors
Recently, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued much-anticipated proposed regulations on the potential 20% qualified business income (QBI) deduction for owners of pass-through entities and sole proprietorships. This proposed guidance provides clarity to certain areas where the statute was vague, but it has also left tax practitioners with some…
Read MoreReducing Capital Gains by Creative Use of SMLLCs and Installment Notes
A popular estate planning technique for estates facing the prospect of incurring federal estate tax has been for a grantor (G) to set up an irrevocable, grantor trust (the Trust) then sell an asset (e.g. an interest in a partnership [PSP]) to the Trust, taking back an installment note. As an irrevocable trust, the asset…
Read MoreChoosing the Right Reservation System for your Restaurant
Love ’em or hate ’em, reservations are a critical facet of the restaurant business. With new advances in industry technology, pen-and-paper reservation systems are looking rather old-school. New trends in data tracking and customer service have made automated restaurant systems more customizable and cost-effective for restaurants of all sizes. Reserving Peace of Mind Reservations provide…
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