Net Operating Losses

STATE TAX KNOWLEDGE UPDATE (54 ITEMS) - JULY 3, 2018

The following are state tax and business developments I have curated since June 11th, and posted in the LEVERAGE SALT LinkedIn group:

Some of the items may be on the same state/issue/topic, but they are from different sources which may give you a broader perspective to help your company or client.

  1. High Court Will Not Review Pennsylvania NLC Carryover Decision

  2. North Carolina Budget Bill Makes Major Tax Changes, Updates Conformity

  3. Colorado Issues IRC Sec. 965 Repatriation Transition Tax Guidance

  4. Connecticut Issues Guidance on Pass-Through Entity Tax

  5. Connecticut Issues Guidance on Bonus Depreciation Changes

  6. Hawaii Enacts Sales Thresholds for Sales Tax

  7. Hawaii Updates IRC Conformity for 2018

  8. Chicago Tax on Streaming Services Upheld

  9. Virginia Enacts Biennial Budget Legislation

  10. Are High Court Tax Precedents Set in Stone After 25 Years?

  11. DON'T PANIC - Physical Presence No Longer Matters in Determining Whether A Company is Required to Collect Sales Tax

  12. North Dakota Remote Seller Thresholds Take Effect With Quill Overturn

  13. Louisiana Enacts Remote Seller Law

  14. Minnesota Offers Wayfair Guidance

  15. What will non-streamlined sales tax states do??

  16. STOP THE USE TAX NOTICE AND REPORTING LAWS!!!!

  17. California OTA Issues Revised Draft Proposed Permanent Regulations on Administration and Procedures of Appeals and Petitions for Rehearing

  18. Louisiana: New Law Clarifies that Certain Reductions and/or Suspensions of Tax Benefits, Credits, and Exemptions Enacted via 2015 Legislative Changes were Temporary

  19. North Carolina: New Law Updates State Conformity to IRC, Responds to Some Provisions of the Federal 2017 Tax Act, and Revises Sales Factor Sourcing Rules

  20. US Supreme Court Denies Taxpayer’s Request to Review 2017 Pennsylvania Supreme Court Ruling on NOL Carryovers

  21. Rhode Island Division of Taxation Releases Guidance on Treatment of IRC Sec. 965 Income for C Corporations, and Accompanying Proposed New Regulation

  22. Texas Appellate Court Holds that Taxpayer Provides Services Rather than “Goods” for Purposes of Calculating Deductible Costs of Goods Sold under Franchise Tax

  23. Alabama Issues IRC Sec. 965 Repatriation Income Guidance

  24. Decoupling Bill Sent to New Jersey Governor

  25. New Jersey Legislature Passes Tax Amnesty Bill

  26. Rhode Island Budget Bill Amends Personal Exemptions, Credits

  27. Connecticut Creates Deduction for Venture Capital Income

  28. Iowa Offers Wayfair Guidance

  29. Louisiana Decreases Sales Tax Rate

  30. New Jersey Legislature Passes Alternative Surtax and Decoupling Bill

  31. Massachusetts Bill Creates Family and Medical Leave Payroll Tax

  32. Remote Sellers Not Yet Required to Collect Tax From South Dakota Buyers

  33. Vermont’s Remote Seller Law Takes Effect July 1

  34. Corporate Close-Up: Colorado Latest State to Enact Market-Based Sourcing

  35. Hawaii Explains Nexus Thresholds

  36. Kentucky Provides Wayfair Guidance

  37. Rhode Island Outlines Remote Seller Registration Options

  38. Vermont Reduces Rates, Updates IRC Conformity

  39. Idaho Is Reviewing Impact of Wayfair Decision

  40. New Hampshire Responds to Wayfair Decision

  41. Pennsylvania Decouples Corporate Income Tax from Federal Bonus Depreciation

  42. NCSL says states should ensure that they are fully prepared before begin enforcing their sales tax laws on remote sellers

  43. New Jersey Enacts Tax Amnesty Bill

  44. New Jersey Enacts Surtax, Combined Reporting, and Decoupling

  45. Colorado DOR Discusses State Treatment of Foreign Earnings Subject to New Federal Transition Tax under IRC §965

  46. Hawaii: New Law Updates State Conformity to Internal Revenue Code, Responds to Some Provisions of the Federal 2017 Tax Act

  47. Illinois DOR Issues Proposed Amended and New Rules on Prior Year NOL Suspensions and Special NOL Computation Rules

  48. New York: Draft Proposed Article 9-A Franchise Tax Regulations Issued on Corporations Subject to Tax

  49. New Jersey Appellate Court Affirms that IRC Tax Attribute Reductions May Not be Reversed

  50. Alabama DOR Issues Additional Guidance on IRC Sec. 965 Transition Tax’s Impact on State Tax Returns

  51. California: FTB Explains New Policy Prohibiting Certain Ex Parte Communications Involving Alternative Apportionment Petition Hearings

  52. Rhode Island: New Law Grants State Tax Administrator Additional Authority in Light of Federal 2017 Tax Act

  53. Louisiana: New Law Includes Tax Rate Reduction and Various other Changes

  54. Rhode Island: New Law Imposes Tax on Sales of Software as a Service (SaaS)

The above represents 'general curating' of state tax developments into one spot. If you still feel overwhelmed by the volume of state tax developments, please consider my 'custom curating' service. Meaning, clients hire LEVERAGE SALT to daily curate state tax developments relating to a specific industry, state(s), tax type and issueYou can make it as granular as you prefer. This allows you to reduce information overload, and only get the information you need to help your clients or company. This service is provided on a fixed-fee or subscription basis. Contact me at strahle@leveragesalt.com.

STATE TAX KNOWLEDGE UPDATE (59 ITEMS) - May 22, 2018

The following are state tax and business developments I have curated since May 2nd, and posted in the LEVERAGE SALT LinkedIn group:

Some of the items may be on the same state/issue/topic, but they are from different sources which may give you a broader perspective to help your company or client.

  1. Wisconsin Explains Reconciliation with Federal Consolidated Returns

  2. Preview of the share image State Sales Tax Shakeup

  3. Indiana Offers Voluntary Disclosure Initiative for Out-of-State Retailers

  4. Kentucky Requires IRC Sec. 199A Addback, Restores Credits

  5. South Dakota Provides Guidance on Foreign Dividend Recapture

  6. MTC Section 18 Alternative Apportionment Regulatory Project Moves Forward with Two Proposed Model Rules - Draft Model Use Tax Reporting Statute Also Advances

  7. Alabama DOR Issues Guidance on IRC Sec 965 Transition Tax Impact on State Tax Returns

  8. California FTB Moves Forward with New Draft Proposed Amendments to Market-Based Sourcing Regulation

  9. Florida DOR Issues Guidance on IRC Sec 965 Transition Tax Impact on State Corporate Tax Returns

  10. New Kentucky Law Imposes Mandatory Unitary Combined Reporting Regime

  11. Ohio Supreme Court Holds in Taxpayer Favor Regarding Credit Computation for Pre-CAT NOLs

  12. Oregon DOR Issues Proposed Administrative Rule on New State Repatriation Tax Credit Pursuant to IRC Sec 965 Repatriation Income for Tax Year 2017

  13. Growing Number of State Sales Tax Jurisdictions Makes South Dakota v. Wayfair That Much More Imperative

  14. Oklahoma Allows Transition Tax Installment Payment Election

  15. Tax Reform Task Force Names Income Tax Proposals for Further Study

  16. California OTA Readopts Emergency Rules on Administration and Procedures of Appeals and Petitions for Rehearing

  17. Focusing the Lens on Film Credits

  18. Indiana DOR Offers Special Limited-Time VDI for Out-of-State Online Retailers with In-State Inventory

  19. New Georgia Law Addresses Federal Partnership Audit Regime Changes and How to Report Adjustments for State Purposes

  20. Taxpayer Asks US Supreme Court to Review 2017 Pennsylvania Supreme Court Ruling on NOL Carryovers

  21. South Dakota DOR Discusses Federal Tax Law Changes Relating to Foreign Dividend Recapture and Potential Impact for State Bank Tax Purposes

  22. Texas Comptroller Issues Franchise Tax Ruling on Whether Proceeds from Certain Hedging Transactions Are Included in Apportionment Factor

  23. Alabama DOR Discusses New Law Requiring Certain Marketplace Facilitators to Collect and Remit Tax

  24. New Georgia Law Requires Some Remote Sellers to Collect and Remit Tax or Else Adhere to Information Reporting Requirements

  25. California FTB Issues Final Report on California’s Conformity to 2017 Federal Income Tax Changes

  26. State and Local Tax Technology Checklist (Techlist)

  27. TWIST - This Week in State Tax

  28. Georgia Expands “Dealer,” Adds Use Tax Notice Requirement

  29. Alabama Opens for Amnesty Applications on July 1

  30. Connecticut Legislature Approves Pass-Through Entity Tax

  31. Legislative Session Review: Georgia

  32. California May 18 meeting on changes to market based sourcing rules

  33. Connecticut Requires Bonus Depreciation, Sec. 179 Adjustments

  34. IRC Conformity Bill Goes to Hawaii Governor

  35. Indiana Special Session Considers IRC Conformity

  36. North Carolina Proposes Income Tax Rate Changes

  37. Legislative Session Review: Kansas

  38. Indiana Enacts IRC Conformity Bill

  39. Indiana Revises Corporate Income Tax Rate Calculation and Credit

  40. Massachusetts Provides Estimated Tax Penalty Relief for IRC Sec. 965 Income

  41. Oklahoma Creates New Credits for Vehicle Manufacturing Industry

  42. “One Maryland” Credit Revised

  43. Maryland Retains Personal Exemptions

  44. Alabama DOR Reminds that 2018 Amnesty Program Begins July 1

  45. Kentucky Claims Commission Amends Rules Related to Tax Appeals Procedures

  46. Alabama DOR Issues Amended Rules on NOL Carryforwards and Revised Filing Due Dates

  47. Updated Connecticut Administrative Guidance Discusses Treatment of IRC Sec 965 Federal Repatriation Transition Tax

  48. New Indiana Law Updates State Conformity to IRC

  49. Massachusetts DOR Issues Release on Estimated Tax Penalty Relief for Corporations Affected by Transition Tax on Deferred Foreign Earnings

  50. New Oklahoma Law Permits Electing Federal Transition Tax Installment Payers to Elect Similar Payment Scheme for State Purposes

  51. Pennsylvania DOR Announces that 2017 State Supreme Court Ruling on NOL Carryovers Will Not Be Applied to Earlier Years

  52. City of Seattle Poised to Impose an Employee Hours Tax on Some Businesses

  53. Alabama Tribunal Judge Denies DOR Motion to Stay in Online Retailer Legal Challenge of Economic Presence Rule for Out-of-State Sellers Making Threshold Sales into Alabama

  54. New York eyes UBT in response to federal tax reform

  55. Pennsylvania Clarifies Caps for NOL Calculations

  56. California Requires Return Adjustments for Sec. 965 Amounts

  57. Minnesota Legislature Passes IRC Conformity, Rate Reductions

  58. Friday Tax Reform: States Issue Guidance, Waive Penalties for Foreign Income

  59. Corporate Close-Up: Indiana Latest State to Respond to Federal Tax Reform

The above represents 'general curating' of state tax developments into one spot. If you still feel overwhelmed by the volume of state tax developments, please consider my 'custom curating' service. Meaning, clients hire LEVERAGE SALT to daily curate state tax developments relating to a specific industry, state(s), tax type and issueYou can make it as granular as you prefer. This allows you to reduce information overload, and only get the information you need to help your clients or company. This service is provided on a fixed-fee or subscription basis. Contact me at strahle@leveragesalt.com.

STATE TAX KNOWLEDGE UPDATE (70 ITEMS) - MARCH 13, 2018

The following are state tax and business developments I have curated since February 7th, and posted in the LEVERAGE SALT LinkedIn group:

Some of the items may be on the same state/issue/topic, but they are from different sources which may give you a broader perspective to help your company or client.

  1. Sweeping New Iowa Tax Policy Unveiled

  2. Idaho Enacts New IRC Conformity Date

  3. Georgia Introduce IRC Conformity Bill

  4. West Virginia Passes Federal Conformity Bill

  5. Sales Subject to Indiana Throwback Rule

  6. Idaho Sends IRC Conformity Legislation to Governor

  7. Kansas Might Repeal Multistate Tax Compact Provisions

  8. Corporate Close Up: D.C. Denies Big Oil Summary Judgment on Multimillion-dollar Chainbridge Transfer Pricing Case

  9. Tax Reform Friday: High Income Tax States Strike Back Against Limitation of State Tax Deduction

  10. Individual Income Insights: Many States Mulling Conformity to “Fit In”

  11. Extras on Excise: States are Smitten for Fuel Tax Revenue

  12. Sales Tax Slice: Sourcing Online Purchases from Physical Stores

  13. Effective NOL Planning in Light of Tax Reform | Tax Executive

  14. Pennsylvania DOR Issues Non-Participation Penalty Assessments to Delinquent Taxpayers that Failed to Partake in 2017 Tax Amnesty Program

  15. The Empire State is Open for Business – Overview of Select New York Credits and Incentives

  16. Nexus Considerations: Navigating the "Kill Quill" Revolt

  17. District of Columbia Confounds Opposition to Its Transfer Pricing Strategy

  18. Implications to Illinois Repeal and Replacement of Its Unclaimed Property Act

  19. Louisiana Governor Calls Special Session to Address Fiscal Cliff

  20. COST: State-by-State Scorecard Summaries and State Legislative Targets

  21. 2018 State Tax Amnesty Programs

  22. 2017 State Tax Amnesty Programs (in case you missed it)

  23. COST’s Opposition to House Bill 2489, Retroactive Repeal of Multistate Tax Compact Provisions

  24. COST’s Opposition to Senate Bill 227, Mandatory Unitary Combined Reporting

  25. California Issues Out-of-State Voluntary Disclosure Application

  26. Idaho Enacts New IRC Conformity Date

  27. Tax Reform Friday: Idaho and West Virginia Take Differing Approaches to I.R.C. Conformity Post-Pub. L. No. 115-97

  28. West Virginia IRC Conformity Date Updated

  29. Virginia Enacts IRC Conformity Legislation

  30. Corporate Close-Up: California Holds LLC Member Responsible for Entitys Tax Liabilities

  31. Extras on Excise: By Taxing Uber and Other TNCs, Alabama Joins the Club

  32. Corporate Close-Up: New York City Tribunal Rules on Sourcing of Services from Subscription-Based Consulting

  33. Property Tax Post: Payment in Lieu of Tax Already a Success?

  34. Individual Income Insights: Many States Mulling Conformity to “Fit In”

  35. Court or Congress? State Online Sales Tax Power Set for Change

  36. Update: Companies Face Setback in Challenge to District of Columbia’s Use of Chainbridge Transfer Pricing Method

  37. Congress Extends Tax Incentives for Energy Production and Conservation

  38. 2018 STATE LEGISLATIVE SESSION CALENDAR

  39. MTC Files Brief in Support of South Dakota’s Petition in Wayfair Case

  40. Could States Fix The SALT Deduction Cap By Taxing Pass-Throughs and Giving Their Owners A Credit?

  41. Ohio Department of Taxation Reissues Release on Nexus Standards and Filing Safe Harbors for Pass-Through Entities

  42. Partnership Not Liable for Nonresident Partner’s NJ Tax

  43. Michigan Explains Apportionment of Industrial Processing Exemption

  44. Federal Tax Reform—Multistate Tax Considerations and Conformity

  45. Colorado DOR Holds that Alternative Apportionment is Warranted Under Taxpayer Provided Facts

  46. District of Columbia CFO Addresses How Recently Enacted Federal Tax Reforms May Affect Some Taxation in the District

  47. New Idaho Law Specifies 120-Day Timeframe to Report Federal Tax Audit Adjustments

  48. New Virginia Law Updates State Conformity to IRC and Decouples from Some Provisions of the 2017 Federal Tax Reform Act

  49. New West Virginia Law Updates State Conformity to IRC

  50. US Supreme Court Schedules Oral Arguments in Case Challenging the Constitutionality of Remote Seller Economic Nexus Law for April 17

  51. Colorado DOR Issues General Information Letter Addressing Certain Remote Seller Notice and Reporting Requirements

  52. South Carolina DOR Announces Acceptance of Retail Sales Tax Applications from Third-Party Suppliers of Products Sold via Online Marketplace Provider Website to In-State Purchaser

  53. Could Colorado actually simplify its sales tax system? Let's hope so.

  54. Tax Reform Friday: More Tax Reform Bills and Proposals; Texas v. ACA–Round 2

  55. Corporate Close-Up: ‘Kill Quill’—What the End of Quill Would Mean for Corporate Income Taxpayers

  56. Georgia Enacts IRC Conformity Update, Rate Cut

  57. Michigan Keeps Personal Exemptions

  58. Oregon Tax Bill Includes IRC Conformity

  59. Illinois Introduces Marketplace Fairness Act

  60. Alabama Tax Amnesty Program Enacted

  61. New Alabama Law Requires 2018 Amnesty Program Providing for Potential Waiver of Interest and Penalties

  62. Michigan Department of Treasury Explains New Law Permitting Alternate Method of Dispute Settlement and Resolution for Certain Tax Liabilities

  63. California FTB Explains Refund Claim Procedures Pursuant to 2017 Appellate Court Ruling

  64. New Georgia Law Updates State Conformity to IRC

  65. Illinois DOR Addresses How Recently Enacted Federal Tax Reforms May Affect Some State Income Taxation

  66. New Michigan Law Generally Updates State Conformity to IRC and Permits Taxpayer Election to Conform to IRC in Effect for Tax Year

  67. Partnership Not Liable for Out-of-State Limited Partner CBT in New Jersey

  68. Connecticut DOR Services Sends Use Tax Notices to Online Customers Based on Information Provided by Online Retailers

  69. Chart of States with and without State Tax Tribunals (as of 2/3/16)

  70. Florida Reaches Agreement on IRC Conformity, Other Tax Issues

The above represents 'general curating' of state tax developments into one spot. If you still feel overwhelmed by the volume of state tax developments, please consider my 'custom curating' service. Meaning, clients hire LEVERAGE SALT to daily curate state tax developments relating to a specific industry, state(s), tax type and issueYou can make it as granular as you prefer. This allows you to reduce information overload, and only get the information you need to help your clients or company. This service is provided on a fixed-fee or subscription basis. Contact me at strahle@leveragesalt.com.

State Tax Knowledge Update (41 items) - January 6, 2018

Happy New Year! 

I hope you are off to a great start (despite the extreme cold and snow many of you have been experiencing).  Be safe out there.

As we start the new year with federal tax reform finally enacted, we will begin to have to deal with the details, and how states will respond. This year's state legislative season should be very interesting. The District of Columbia and Pennsylvania have already provided some responses (see #30 and #32 below).

The following are state tax and business developments I have curated since December 12, and posted in the LEVERAGE SALT LinkedIn group:

Some of the items may be on the same state/issue/topic, but they are from different sources which may give you a broader perspective to help your company or client.

  1. Income-producing activity of cable company is as licensee

  2. Seattle Income Tax Ruled Invalid

  3. Connecticut Fresh Start Program Has Begun

  4. Florida DOR Issues Guidance on Voluntary Disclosure Program

  5. Amended Alabama Rule Reflects New Law that Includes Loans and Credit Card Receivables in Property Factor for FIET Purposes

  6. New California FTB Policy Prohibits Certain Ex Parte Communications Involving Alternative Apportionment Petition Hearings

  7. Arkansas Taxpayers Reminded that New Law Taxes Specified Digital Products and Digital Codes Beginning January 1

  8. Ohio Supreme Court Holds that Preparation of Company Gift Sets for Retailers Qualifies as Exempt Assembly Under Manufacturing Exemption

  9. Washington DOR Issues Amended Business and Occupation Tax Rules on Financial Institution Apportionment to Conform with MTC Changes

  10. Corporate Close-Up: New Jersey Court Rules That State Cannot Impose Corporate Business Tax on Foreign-Source Income Not Subject to United States Federal Income Tax

  11. Tennessee DOR Subjects Cloud-Based Employee Scheduling Services to Sales and Use Tax

  12. City of Chicago Department of Finance has changed the terms of its voluntary disclosure program

  13. Trends in State Tax Policy, 2018

  14. How States May React to Federal Tax Reform

  15. Illinois updates the Revised Uniform Unclaimed Property Act

  16. California Tax Update 2017

  17. California Office of Tax Appeals Releases Final Draft Emergency Regulations on Rules for Tax Appeals

  18. The 2018 National Multistate Tax Symposium

  19. California OTA Issues Amended Proposed Emergency Regulations on Administration and Procedures of Appeals and Petitions for Rehearing

  20. Indiana DOR Explains Success of its New Protest Review System

  21. New Michigan Law Permits Alternate Method of Dispute Settlement/Resolution for Certain Tax Liabilities

  22. Texas Comptroller Announces that Recently Enacted Tax Amnesty Program will Run from May 1 to June 29 Providing for Potential Waiver of Penalties and Interest

  23. California FTB Updated New Policy Prohibits Certain Ex Parte Communications Involving Alternative Apportionment Petition Hearings

  24. Massachusetts DOR Issues Proposed Regulations on Corporate Excise Tax Nexus

  25. New Ohio Law Imposes Preferential Tax Rate on Certain Wages and Guaranteed Payments Paid by PEOs to Certain Owners of Pass-Through Entities

  26. Texas Supreme Court Affirms Rejection of Taxpayer Use of Multistate Tax Compact Evenly-Weighted

  27. CDTFA Discusses Expanded Partial Sales and Use Tax Exemption

  28. Minnesota DOR Discusses New Law Imposing Collection and Remittance Responsibilities on Marketplace Providers

  29. Ohio Trade Association Files Suit Challenging Validity and Enforcement of New Remote Seller Economic Nexus Law as Interpreted by Department of Taxation

  30. PA Department of Revenue Bulletin: Federal 100 Percent Expensing Deduction Disallowed

  31. Texas Supreme Court - Multistate Tax Compact three-factor election denied

  32. District of Columbia Takes First Step to Decouple from Federal Tax Reform

  33. State Strategies to Preserve SALT Deductions for High-Income Taxpayers: Will They Work?

  34. State Tax Changes That Took Effect on January 1, 2018

  35. Texas Tax Amnesty Begins May 1, 2018

  36. Texas Supreme Court Denies Three-Factor Apportionment in Graphic Packaging

  37. Federal tax reform and the states: Conformity is key

  38. New York City small businesses to receive Commercial Rent Tax benefits

  39. Indiana-based online participant revenue properly sourced out of state

  40. Ohio Supreme Court affirms decision on employment service exemption

  41. Pennsylvania provides guidance on the corporate NOL limitation

The above represents 'general curating' of state tax developments into one spot. If you still feel overwhelmed by the volume of state tax developments, please consider my 'custom curating' service. Meaning, clients hire LEVERAGE SALT to daily curate state tax developments relating to a specific industry, state(s), tax type and issueYou can make it as granular as you prefer. This allows you to reduce information overload, and only get the information you need to help your clients or company. This service is provided on a fixed-fee or subscription basis. Contact me at strahle@leveragesalt.com.

How States May React to Federal Tax Reform

I hope you had a great Christmas, and are looking forward to 2018.

Last week, the President signed tax reform (H.R. 1) into law making the most dramatic overhaul to our federal tax code since 1986. I normally focus on state taxes, but I have been analyzing the federal tax reform changes for specific clients and doing some ghost-writing. 

Here I want to provide you with some predictions as to how the states may respond to some of the main business federal tax changes.

  1. New federal tax law allows 100% expensing of short-lived capital investments, such as machinery and equipment (for 5 years) - applies to qualified property placed in service after 9/27/17 and before 2023. States will most likely NOT conform to this provision and require businesses to add-back the federal deduction.
  2. New federal tax law raises Section 179 small business expensing cap to $1 million with a phaseout starting at $2.5 million. States will most likely NOT conform to this provision and require businesses to add-back the federal deduction.
  3. New federal tax law eliminates net operating loss (NOL) carrybacks while providing indefinite net operating loss carryforwards, limited to 80 percent of taxable income. Most states don't use the federal NOL and compute their own state NOL, and thus, will most likely not conform to this change. However, there are a handful of states that use the federal NOL and do not compute a separate state NOL. These states will have to make a decision as to whether to conform to the federal changes. I think these states will most likely conform. (For more info on state NOLs, see my previous post)
  4. Under the new federal tax law, research expenses are required to be amortized and the domestic production deduction (Sec. 199) was repealed. States will most likely conform to these changes.
  5. The new federal tax law creates a new 20% deduction for pass-through entities. The calculation for this new deduction is extremely complex and has several limitations. States that are impacted negatively (i.e., obtain less tax revenue) by this deduction will most likely NOT conform. (Here is a link to an article by the Tax Foundation - Pass-Through Deduction Won’t Flow Through to Most States)

Those are the top 5 business tax changes (other than the tax rate changes and tax changes for foreign income) that I believe the states will address specifically. 

Have a Happy New Year and remember - you can't keep doing the same things and expect a different result! Change can be good. Start now.

State Tax Knowledge Update (37 items) - Sept 21, 2017

The following are state tax and business developments I have curated since September 12th, and posted in the LEVERAGE SALT LinkedIn group:

Some of the items may be on the same state/issue/topic, but they are from different sources which may give you a broader perspective to help your company or client.

  1. VA sourcing rules constitutional IPA where work performed

  2. AL group may use NOLs generated before consolidated election

  3. State Rundown 9/13: The Year of Unprecedented State Budget Impasses Continues

  4. Comments on South Dakota’s Challenge to Quill

  5. Domestic tax quarterly webcast series: a focus on state tax matters

  6. South Dakota Supreme Court – Sales tax economic nexus provisions unconstitutional; appeal to US Supreme Court expected

  7. Virginia Denies Alternative Market Approach for Sourcing Sales

  8. South Dakota Supreme Court Rules in Favor of Remote Retailers; Next Step US Supreme Court?

  9. Florida Provides Guidance Regarding Sourcing of Services for Income Tax Purposes

  10. Pennsylvania Department of Revenue Attempts to Tax Information Retrieval Services: An Overview of Letter Ruling SUT-17-002

  11. Foxconn Tax Credit Package Enacted in Wisconsin

  12. Zapper Fraud Case Results in Mandatory Real-Time Monitoring

  13. INDIVIDUAL INCOME INSIGHTS: CHECKING UP ON CHECKOFFS

  14. CORPORATE CLOSE-UP: VIRGINIA COURT DENIES CORPORATION USE OF ALTERNATIVE METHOD OF APPORTIONMENT

  15. PROPERTY TAX POST: ARE STATES TAKING THEIR TAKINGS POWER TOO FAR?

  16. CORPORATE CLOSE-UP: ILLINOIS (FINALLY!) FINALIZES MARKET-BASED SOURCING REGULATIONS

  17. INDIVIDUAL INCOME TAX INSIGHTS: INCOME TAX CONSEQUENCES OF NONRESIDENT TELECOMMUTING

  18. CORPORATE CLOSE-UP: THE FTB’S SMALL CAP SOLUTION TO ALLEGED FINANCIAL AND NON-FINANCIAL COMBINED REPORTING APPORTIONMENT DISTORTION

  19. CORPORATE CLOSE-UP: DELAWARE CONTINUES DEVELOPING UNCLAIMED PROPERTY RULES

  20. State Tax Filing Relief for Victims of Hurricanes Harvey and Irma

  21. Examining the Potential Tax Implications of Streaming Video Distribution

  22. Alabama Appellate Court Affirms that Certain Separate Company NOL Carryforwards Can Be Claimed on Consolidated Return

  23. New Delaware Law Includes Retroactive Tax Law Changes for Series Captive Insurance Companies

  24. Illinois Tax Tribunal Holds that Insurance Premium Financing Subs Must File as Part of Combined Return for Financial Organizations

  25. New Mississippi Law Allows Department of Revenue to Contract with Third-Party Auditors on a Contingent Fee Basis

  26. Proposed Regulations Reflect Recent Montana Law Changes that Expand Waiver of Composite Return or Withholding for Domestic Second-Tier Pass-Through Entities

  27. Pennsylvania Trial Court Finds NOL Cap is Unconstitutional

  28. Tennessee DOR Issues Chart and Examples Depicting Apportionment Calculations Under Various Elections

  29. Virginia Circuit Court Denies Alternative Apportionment Request and Upholds Validity of Standard Cost-of-Performance Method to Apportion Income from Subscription-Based Services

  30. Massachusetts DOR Finalizes New Regulation Adopting Bright Line Nexus for Some Remote Sellers

  31. Proposed Amended Ohio Rule Addresses Bad Debts, Assignment of Accounts Receivables, and Financing Companies

  32. Illinois DOR Proposes Use Tax Nexus Standards for Trade Show Retailers

  33. DON'T MISS the 24th Annual Paul J. Hartman SALT Forum

  34. 2017 Oregon Legislative Tax Update

  35. How Much Does Your State Collect in Corporate Income Taxes Per Capita?

  36. REMINDER: Supreme Court to Consider West Virginia Tax Credits Case

  37. Maine: 2017 Legislative Changes

The above represents 'general curating' of state tax developments into one spot. If you still feel overwhelmed by the volume of state tax developments, please consider my 'custom curating' service. Meaning, clients hire LEVERAGE SALT to daily curate state tax developments relating to a specific industry, state(s), tax type and issueYou can make it as granular as you prefer. This allows you to reduce information overload, and only get the information you need to help your clients or company. This service is provided on a fixed-fee or subscription basis. Contact me at strahle@leveragesalt.com.