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Nov 11, 2010 · Two tax concepts that states may employ to increase their tax revenue and that trap unwary foreign entities are (1) unitary combined reporting and (2) economic nexus. Unitary combined reporting is a methodology for apportioning the business income of a corporation that is a member of a unitary business group.
- Colorado Court Rules on Combined Report Inclusion For 80/20 Companies
- Colorado Voters Approve A Ballot Measure to Reduce Corporate Income Tax
- Florida Rules in Favor of The Taxpayer in Revenue Sourcing Case
- Indiana Issues Guidance on Foreign Source Dividend Deduction
- New Jersey Releases Updated Guidance on Income Excluded Under The Tax Treaty
- Oklahoma Issues Regulations Reflecting 100% Bonus Depreciation
- Philadelphia Extends Net Operating Loss Carryforward Period
- Philadelphia Reduces 2022 Birt Tax Rate
- Portland Market-Based Sourcing Provisions Take Effect
In an unpublished opinion announced on Nov. 17, 2022, the Colorado Court of Appeals clarified how companies should determine whether foreign affiliates meet the definition of an “includable corporation” required to file as part of a Colorado water’s edge combined group. The state’s rules require the inclusion of any commonly owned corporation that ...
In the general election held on Nov. 8, 2022, Colorado voters approved Proposition 121, a ballot measure that reduces the state’s corporate income tax rate to 4.40% from 4.55%. The rate change is effective for tax years beginning on or after Jan. 1, 2022.
In a decision dated Nov. 28, 2022, a Florida circuit court ruled that a taxpayer correctly sourced service revenue using a cost-of-performance (COP) approach. The taxpayer provided a variety of merchandising and marketing services to an affiliated entity under an intercompany agreement. Most of the payroll expense associated with providing these se...
In November 2022, Indiana published Income Tax Information Bulletin #78, which provides clarifying guidance on the definition of foreign source dividends and the computation of the associated deduction for Indiana corporate income tax purposes. The definitions in the guidance clarify that “foreign source dividend” includes Subpart F income as well ...
On Dec. 1, 2022, New Jersey published online guidancerelated to the inclusion of foreign income subject to income tax treaty protection in the computation of net income for combined filing groups. The updated guidance clarifies prior guidance issued by the state and provides that taxpayers filing on a worldwide basis for corporation business tax pu...
On Sept. 27, 2022, Oklahoma Tax Commission issued emergency new and amended rules to reflect bonus depreciation changes enacted in May 2022 with the passage of HB 3418. Under the new law, taxpayers may elect 100% bonus depreciation for Oklahoma purposes for tax years beginning after Dec. 31, 2021. The new regulations clarify that to the extent full...
On Nov. 3, 2022, Pennsylvania enacted HB 324, which extends the carryforward period for net operating losses generated for the purposes of Philadelphia’s Business Income and Receipts Tax (BIRT). Losses generated in tax year 2022 may now be carried forward up to 20 years; losses incurred before 2022 remain subject to a three-year carryforward.
On Nov. 9. 2022, the mayor of Philadelphia signed Ordinance No. 220660, reducing the BIRT tax rate applicable to the tax year 2022 to 5.99% from 6.2%. The amendment serves to correct an error in the original rate reduction legislation enacted in June of 2022. The tax rate applicable to tax years 2023 and beyond remains at 5.99%.
On Oct. 13, 2022, the governing bodies of Multnomah County and the Metropolitan Service District(Metro) in Oregon adopted market-based sourcing rules for sales other than sales of tangible personal property. The city of Portland previously enacted market-based sourcing rules in September of 2022, but the provisions were scheduled to take effect onl...
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Jan 1, 2022 · First, the maximum individual income tax rate permitted by the state constitution decreased from 6 percent to 4.75 percent. Second, the amendment eliminated the mandatory deduction of federal income taxes from state income taxes.
Nov 29, 2022 · The Court, in relatively more modern times, continued to broaden the unitary business concept in Mobil Oil Corporation, where the Court upheld applications of the unitary business principle as justification for inclusion of dividend income from foreign affiliates in the apportionable tax base. 3 The prevailing test of the unitary business ...
For additional information about these items, contact Mr. Fairbanks at (202) 521-1503 or greg.fairbanks@gt.com. The use of mandatory unitary combined reporting has become increasingly popular among states in recent years, driven by state budgetary shortfalls and the perceived distortion of taxable income by multistate corporations filing ...
May 14, 2024 · When are state income tax returns due? State income tax return deadlines usually mirror the federal deadline in mid-April, but exceptions exist. Residents of Virginia, for example, generally...
For tax years beginning on or after January 1, 2011, a corporation or unincorporated business entity subject to tax and engaged in a unitary business with one or more corporations or unincorporated business entities subject to combination shall calculate its taxable net income derived from this unitary business as its share, attributable to the District, of the apportionable income or loss of ...
