Browse By Tags

The New York City Tax Tribunal held that an out-of-state corporate taxpayer, with an indirect interest in a limited liability company investment fund engaged in business in New York City, had nexus with the City and was subject to tax on capital gain...

The New Jersey Tax Court rejected a taxpayer’s due process claim finding that the Division of Taxation properly issued the notice of assessment. The taxpayer made three arguments: (1) that the Division issued the assessment in the name of the predecessor...

The South Carolina Administrative Law Court found that the taxpayer bank could not deduct net operating loss (NOL) carryforwards when computing its bank tax liability. The taxpayer argued that banks should be allowed to deduct NOLs regardless of whether...

In interpreting an ambiguous statute allowing for a tax credit against the state’s financial institution excise tax (FIET), the Alabama Court of Appeals held in favor of the Department of Revenue’s interpretation. Alabama imposes a 6½% FIET on the net...

The Minnesota Supreme Court held that the state’s standard apportionment method did not fairly reflect the taxpayer’s net income allocable to the state, reversing the Tax Court’s ruling. The taxpayer, a national financial institution, transferred its...

By Charles Capouet and Madison Barnett The New York City Tax Appeals Tribunal held that a bank filing a combined New York City bank tax return properly excluded from its combined group a Connecticut investment subsidiary that primarily held mortgage...

When a company undertakes a financing transaction, federal and state income tax considerations most frequently take priority in the tax department. In certain financing transactions, however, one would be remiss to ignore potential sales tax issues that...

By Liz Cha and Amy Nogid The Utah State Tax Commission ruled that sales to financial institutions in Utah of the right to use online banking software, finance and budget tool software, online bill payment software, mobile banking software, and a mobile...

By Hanish Patel and Marc Simonetti In a Chief Counsel Ruling, the California Franchise Tax Board (FTB) ruled that, for purposes of determining its sale factor, a financial information provider should source the sales of its information services based...

By Charles Capouet and Todd Lard The New Jersey Tax Court ruled on the sourcing of mortgage-related receipts received by a bank and also held that the Division of Taxation could not throw out receipts from the bank’s denominator. The taxpayer...

By Samantha Trencs and Andrew Appleby A South Carolina administrative law judge (ALJ) determined that cell phone insurance is not subject to South Carolina sales tax even though the wireless provider sells it with taxable communication services. Alltel...

By Liz Cha and Timothy Gustafson In its first decision on combined unitary reporting since Vermont adopted combined reporting in 2006, the Vermont Supreme Court held that the AIG insurance group was not unitary with its wholly owned ski resort subsidiary...

by Mark J. Magyar On July 15, 2015, the Consumer Financial Protection Bureau (“CFPB”) published on its website the written testimony of CFPB Director Richard Cordray before the Senate Committee on Banking, Housing, and Urban Affairs. In...

Dont miss Part 1 of the Measuring ROI series: " Using the Payback Approach ", and Part 2: Using the Net-Present-Value Approach , all by Jon Allen The goal of financial management in any company is to maximize the value for its owners. Managers...

Dont miss Part 2 of the Measuring ROI series: Using the Net-Present-Value Approach , by Jon Allen The goal of financial management in a company is to maximize the value of the company’s stock. Managers need ways to determine whether a project...