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Corporate - State

Tax Reform: Invitation to the Weekly Client Update from Alston & Bird

January 8, 2018 By Alston & Bird Tax Team

With tax reform officially upon us, our subject matter experts will take a deeper dive into areas that are critical to your business, such as corporate taxes, international issues, executive compensation and employee benefits, and partnerships.   The 2018 call-in series will kick off on Tuesday, January 9. All seminars will start at 11am ET and last approximately 30 minutes. Click here to RSVP and receive the dial-in information.   [...]Read more

Filed Under: Corporate - Federal, Corporate - State, Employee Benefits, Federal - Corporate Tax Planning, Federal Tax, Partnerships, Tax Policy, Tax Reform Tagged With: corporate, employee benefits, executive compensation, health & welfare, international tax, partnerships, section 965, Tax, tax reform

Connecticut Revenue Commissioner Suggests That States “Ramp Up” Economic Nexus for Sales Tax Purposes

March 31, 2015 By Clark Calhoun

In a provocative op-ed published in the March/April issue of the Journal of Multistate Taxation and Incentives, the Connecticut Commissioner of Revenue Services (Kevin Sullivan) argues that given Congress’s apparent unwillingness to pass the Marketplace Fairness Act, the states should consider taking matters into their own hands and simply act as if Quill is no longer good law. The Commissioner appears to have been emboldened by Justice Kennedy’s concurrence in the U.S. Supreme Court’s recent decision in Direct Marketing Association v. Brohl, No. 13-1032, __ S. Ct. __ (Mar. 3, 2015), in [...]Read more

Filed Under: Controversies - State, Corporate - State, Sales and Use Tax, State & Local Tax Advisory, State Tax Litigation

State and Local Tax Advisory – California Voters Approve Proposition 39, but Significant Questions Remain Regarding How Corporate Taxpayers Can Apportion Their Income

November 12, 2012 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

This advisory discusses the recently approved Proposition 39, a California ballot initiative that requires corporations conducting a multistate business to apportion their income using a single-sales factor apportionment formula beginning January 1, 2013. Two other recent developments in California raise significant questions regarding the effectiveness of Proposition 39’s single-sales factor apportionment requirement. In Gillette Co. v. Franchise Tax Board, the Court of Appeal of California held that a corporate taxpayer could elect to apportion its income using either the statutory formula [...]Read more

Filed Under: Corporate - State, State & Local Tax Advisory, State and Local Planning, State and Local Tax Incentives Tagged With: Proposition 39

Federal Tax Advisory: F Reorganizations and Double Dummies

September 4, 2012 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

This advisory discusses LTR 201222014, which ruled that persons contributing property to a new corporation in exchange for stock can form a control group with other persons contributing the stock of another corporation (target), and therefore enjoy Section 351 nonrecognition treatment. This might seem obvious to practitioners familiar with combined reorganization/351 contributions that were first treated favorably under Section 351 by LTR 9143025. The transaction often takes the form of a double dummy drop down, whereby a new holding company puts the contributed property in one subsidiary and holds [...]Read more

Filed Under: Corporate - Federal, Corporate - State, Federal - Corporate Tax Planning, Federal Tax Advisory, Uncategorized Tagged With: Section 351

State & Local Tax Advisory: Gillette: Not Exactly a Close Shave – California Court of Appeal Approves Taxpayers’ Compact Elections, Leaving FTB in a Lather

July 26, 2012 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

It was perhaps viewed as a close shave prior to the California Court of Appeal’s issuance of its opinion in Gillette Co. & Subsidiaries v. Franchise Tax Board, No. A130803 (Ct. App., July 24, 2012), but in fact, the court soundly rejected the California Franchise Tax Board’s (FTB) arguments that taxpayers were not entitled to make a so-called “Compact election” and file California tax returns using the Uniform Division of Income for Tax Purposes Act’s (UDITPA) equally-weighted, three-factor apportionment formula. This advisory explains how the court’s decision [...]Read more

Filed Under: Controversies - State, Corporate - State, State and Local Planning, State and Local Tax Incentives, State Tax Litigation

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