Tax Law

Recent Posts

Out of State Taxpayer’s Gain on Minority Ownership Interest in Limited Partnership Subject to Tax.
Posted on 12 Oct 2020 by Eversheds Sutherland LLP

A New York City Administrative Law Judge held that a New Jersey S corporation (“Taxpayer”) was subject to New York City general corporation tax (“GCT”) on gain from the sale of a minority limited partner interest in a limited partnership that leased and... Read More

That’s None of Our Business – Idaho Supreme Court Rules Holding Company’s Gain from Sale of LLC Interest is Nonbusiness Income
Posted on 6 Jul 2020 by Eversheds Sutherland LLP

On May 22, 2020, the Idaho Supreme Court held that the gain realized by a corporate holding company on the sale of its 78.54 percent ownership interest in an LLC was nonbusiness income and therefore not subject to apportionment in Idaho. The LLC was formed... Read More

Tennessee Court of Appeals Holds Legal Malpractice Settlement Proceeds are Taxable Business Earnings
Posted on 15 Jun 2020 by Eversheds Sutherland LLP

The Tennessee Court of Appeals held that a manufacturer’s proceeds from a legal malpractice action are business earnings subject to the Tennessee excise tax. The malpractice action arose when the taxpayer’s attorneys improperly filed a European patent... Read More

New Jersey Tax Court Concluded SMLLC’s Share of Partnership Loss Not Business Loss
Posted on 17 Mar 2020 by Eversheds Sutherland LLP

The New Jersey Tax Court ruled that an individual owner of a single-member limited liability company (“SMLLC”) correctly reported his distributive share of partnership income reported by the SMLCC. The SMLLC owned a 50% interest in a partnership that... Read More