New York Expands Federal Income Tax Benefits for Certain Pass-Through Entity Owners

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By: Jeff Glickman, SALT Partner At a glance The main takeaway: New York State enacted legislation amending the state’s pass-through entity tax and establishing a pass-through entity tax for New York City to expand federal income tax benefits available to its residents. Assess the impact: Pass-through entity tax legislation consistently evolves from state-to-state, making it…

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Texas Supreme Court Rejects the “Receipt-Producing, End-Product Act” Sourcing Test

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At a glance The main takeaway: Some taxpayers may be eligible for a refund after the Texas Supreme Court rejected a “receipt-producing, end-product act” sourcing test for service revenue and instead applied “the location where the taxpayer’s personnel or equipment is physically doing useful work for the customer.” Assess the impact: Taxpayers that applied the…

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If You Received Carried Interests, Profits Interest or a Promote – You Are Subject to a 3-Year Holding Rule

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At a glance The main takeaway: The new regulations under Section 1061 impose a three-year hold on carried interests (also referred to as profits interest and promote), from one year, to qualify for long-term gains treatment for tax years beginning after December 31, 2017. Impact on your business: The modifications to Section 1061 will greatly impact taxpayers…

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Massachusetts SaaS Company Eligible for Single-Factor Apportionment as a Manufacturer

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By: Betsy Goldstein, SALT Manager At a glance The main takeaway: A ruling in Massachusetts concluded that a company’s classification as a manufacturer should not have been revoked on the basis that they sell standardized computer software to customers that is accessed through a Software-as-a-Service platform. As a result, the company saved Massachusetts income taxes…

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