Posts Tagged ‘SALT’
Ohio Nonresident is Required to Apportion Gain from Sale of Equity Interest
By: Betsy Goldstein, SALT Senior Manager At a glance Schedule a free consultation today to learn more! The full story When a nonresident individual sells equity in a business, the gain from that sale is generally sourced to and taxable by the individual’s state of residence. However, there are several situations where another state may…
Read MoreCalifornia Enacts Income Tax Changes to Address the State’s Budget Deficit
At a glance Schedule a free consultation today to learn more! The full story The Governor of California, Gavin Newsome, recently signed two pieces of tax legislation into law. Senate Bill 167 (H.B. 167), signed June 27, 2024, makes several changes to California’s personal and corporate income tax, and Senate Bill 175 (S.B. 175), a…
Read MoreCalifornia Rules that S Corporation’s Sale of a Partnership Interest Resulted in Apportionable Business Income
At a glance Schedule a free consultation today to learn more! The full story: In a recently published decision by California’s Office of Tax Appeals (OTA), an S corporation’s gain on the sale of its interest in an LLC (which was treated as a partnership for income tax purposes) constituted business income subject to apportionment.[1]…
Read MoreArizona Court Reversal: Online Retailer’s Use of In-State Fulfillment Company Created Nexus
By: Tracey Stewart, SALT Associate At a glance Schedule a free consultation today to learn more! The full story: In our July 2023 SALT Newsletter, we wrote an article summarizing an Arizona Tax Court (Tax Court) ruling that an online auto parts distributor that contracted with six third-party fulfillment centers in Arizona did not have…
Read MoreLegislative Update: Alabama and Kansas Amend Pass-Through Entity Tax; Vermont to tax SaaS
At a glance Schedule a free consultation today to learn more! The full story: Alabama and Kansas enacted substantial changes to their pass-through entity (PTE) taxes, and Vermont will begin subjecting SaaS to sales tax. Below is a summary of each state’s legislative PTE tax changes. Alabama PTE tax On April 26, 2024, Alabama Governor…
Read MoreNew York Sales Tax Rulings Continue Hard Line on Bundled Sales that Include Software
At a glance Schedule a free consultation today to learn more! The full story Two recently issued sales tax rulings in New York further solidify the state’s reluctance to apply the primary function test when taxable tangible personal property (e.g., software or SaaS) is sold for a bundled price with nontaxable services. For these types…
Read MoreNew York Court Concludes that Taxpayer is Providing a Taxable Information Service
By: Betsy Goldstein, SALT Senior Manager At a glance Schedule a free consultation today to learn more! The full story: The New York Supreme Court Appellate Division (Court) issued an opinion in which it upheld the Tax Appeals Tribunal’s (Tribunal) decision that the taxpayer (Taxpayer) provided taxable information services.[1] A closer look at the case…
Read MoreTexas Comptroller Raises More Questions After Denying Taxpayer a Cost of Goods Sold Deduction
At a glance Schedule a free consultation today to learn more! The full story In a recent decision issued by the Texas Comptroller (Decision No. 116,007), a taxpayer who engaged in the business of providing aircraft instrument, avionics, and accessory services was denied the ability to claim the cost of goods sold (COGS) deduction in…
Read MoreSouth Carolina Ruling Exempts the Sale and Rental of Digital Textbooks
By: Camille Adams, SALT Senior Associate At a glance Schedule a free consultation today to learn more! The full story: The South Carolina Department of Revenue (DOR) recently issued a private letter ruling addressing whether the sale and rental of digital textbooks are exempt from sales and use tax.[1] A closer look at the case…
Read MoreLegislative Update: Georgia’s 2024 Session Ends & Tennessee Offers Unique Refund Opportunity
At a glance Schedule a free consultation today to learn more! The full story: It’s been a busy spring for Georgia and Tennessee. On March 28, 2024, the Georgia legislative session ended and saw the passage of several notable tax bills. Plus, Tennessee’s franchise tax reform has resulted in a refund opportunity taxpayers won’t want…
Read More