Posts by Kristen Davis

Pursuant to a unique New York provision, a federal S-corporation that did not make a separate New York S-election was treated as a New York S-corporation following a sale of the business in which the parties made a 338(h)(10) election, resulting in a large New York tax assessment against the S-corporation shareholders. By Kristen Davis,…

When selling a business, the receipts from the sale of assets can have a significant impact on the sales factor for apportionment purposes, which is why many states have special rules to address these transactions. By Kristen Davis, SALT Associate Businesses that operate and file income tax returns in multiple states are likely familiar with…

A recent Texas decision imposing sales tax on charges for online games highlights the difficulty of applying old sales tax provisions to new services as well as the importance of responding to requests for information issued by a state taxing authority. By Kristen Davis, SALT Associate The growth in online gaming has exploded over the…