Welcome to the April 2017 issue of the Aprio State & Local Tax (SALT) Newsletter.
With dozens of different taxes imposed by the 50 states (and thousands of local jurisdictions), we recognize how challenging it is to keep up with current issues and developments. This newsletter is designed to provide insights on developments in state and local taxes including new legislation, regulations, rulings and cases addressing issues such as corporate and personal income taxes, sales and use taxes, nexus, franchise/net worth taxes, etc.
This issue of the newsletter includes articles addressing (i) a Michigan notice explaining the new ownership rules for combined groups as a result of a Court of Appeals case and possible prior-year filing requirements, (ii) a Florida administrative ruling on the taxability of drop shipments, (iii) an update on federal mobile workforce simplification legislation and a recent City of Detroit bulletin regarding the taxation of non-resident athletes, (iv) an Arizona letter ruling on the characterization of bill payment services under the transaction privilege tax and (v) federal conformity legislation recently enacted in Georgia and Arkansas.
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If you have any comments, questions or suggestions regarding current or future topics, or if you would like to learn more about Aprio's SALT Practice, please email us at jeff.glickman@aprio.com. Thank you.
Jeff Glickman, J.D., LL.M.
Partner-in-Charge, State & Local Tax Practice
Michigan Explains New Combined Filing Requirements for Unitary Business Groups
By Jeff Weinkle, SALT manager
As a result of a recent Court of Appeals decision that "indirect" ownership doesn't include attributional or constructive ownership, Michigan taxpayers must amend affected returns.
Florida Rules that Drop Shipments Not Taxable When Supplier and Retailer are Located Outside Florida
By Alissa Graffius, SALT senior associate
Florida ruled that the sale for resale transaction was not taxable because both parties had no in-state locations and the goods were delivered from out-of-state.
Detroit Issues Guidance to Assist Non-Resident Athletes Determine City Income Tax Liability
By Jess Johannesen, SALT manager
Athletes will owe Detroit's income tax for the days spent performing their duties in the city, apportioned based on the number of standard "duty days" for the season.
Arizona Rules on Taxability of Transaction Processing Services through Computer Software
By Tina Chunn, SALT senior manager
Arizona ruled a transaction was a non-taxable service instead of taxable software because the taxpayer's client did not have sufficient control or use of the software.
Georgia and Arkansas Enact Federal Income Tax Conformity Legislation
By Jeff Glickman, SALT partner
Georgia brought its income tax code section in line with changes enacted by Congress, and Arkansas eliminated the ability of S-corporations to be treated as C-corporations at the state level.
Aprio's State and Local Tax (SALT) practice advises clients on the state and local tax implications of their business operations, allowing clients to strategically minimize their liabilities and risks. Our team has over 50 years of combined SALT experience working in industry, state departments of revenue, public accounting and private law practice. We specialize in all areas of SALT, including matters related to state tax nexus, corporate and personal income taxes, sales/use tax, franchise/net worth taxes, credits and incentives, and mergers and acquisitions. In addition, we represent clients in administrative matters before state revenue departments around the country, including audit defense and settlement negotiations, pursuing voluntary disclosure agreements and obtaining letter rulings.
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