Incorrect Transfer Pricing Method Used to Calculate Royalty Rates for...
There were insufficient facts for determining that a medical device company’s comparable uncontrolled transactions (CUT) method was the best method for determining the arm’s-length royalty rate to be...
View ArticleWeekly Report from Washington, D.C.
During the week of August 13, Senate Finance Committee (SFC) Republicans clarified congressional intent of certain tax reform provisions. The IRS has provided the 2018 monthly national average premium...
View ArticleMinnesota Corporations May Have to Subtract Deferred Foreign Income on State...
Certain Minnesota taxpayers may be required to subtract federally reported deferred foreign income (DFI) on their state corporate income tax returns. DFI is part of federal taxable income and added to...
View ArticleIllinois Trade Show Nexus: The Safe Harbor
Out-of-state businesses that market their products at several trade shows in Illinois each year could have sales tax nexus with Illinois. Beginning July 27, 2018, these companies have a duty to collect...
View ArticleFactoring and Management Fees Not Deductible Expenses (Pacific Management...
Factoring and management fees paid to the shareholders of four C corporations were not deductible expense. Rather, they were disguised distributions of corporate profits. Therefore, the distributions...
View ArticleAffiliates Without Physical Presence Subject to Oregon Corporate Income Tax
Corporate affiliates, lacking a physical presence in Oregon, were subject to Oregon’s corporate income tax in 2006-2008. The Texas based taxpayer provided motor vehicle financing and was authorized to...
View ArticleInterim Guidance Provided for Exempt Organizations with Multiple Unrelated...
Interim guidance and transition rules have been released regarding the special rule requiring exempt organizations that have unrelated business taxable income from operating more than one unrelated...
View ArticleIRS Provides Guidance on What Constitutes a Covered Employee Under Code Sec....
Taxpayers can rely on new guidance related to the limitation on the deduction for employee compensation in excess of $1 million. Specifically, the guidance addresses – the definition of a covered...
View ArticleIllinois Adds ABLE Tax Deduction
Illinois legislation adds a tax deduction for contributions to qualified ABLE savings accounts. Personal income taxpayers can claim the deduction for tax years: – beginning on or after January 1, 2018;...
View ArticleMassachusetts Increases Earned Income Tax Credit
Massachusetts legislation increases the refundable earned income tax credit (EITC) for low-income individuals. Taxpayers who qualify can claim the credit against Massachusetts personal income tax...
View ArticleMassachusetts Raises Dairy Farmer Credit Cap
Massachusetts raised the statewide cap for the dairy farmer tax credit. In budget legislation, eligible dairy farmers can claim the refundable credit against Massachusetts: corporate excise tax; or...
View ArticleOregon Required Broadcaster to Apportion All Receipts
An interstate broadcaster had to apportion all of its revenue stream receipts according to the Oregon corporate (excise) income tax broadcaster apportionment provisions. The broadcaster apportionment...
View ArticleChemicals Qualified for Washington Sales Tax Exemption
A hydrogen peroxide manufacturer’s purchases of chemicals qualified for the Washington manufacturing machinery and equipment sales tax exemption. Devices The taxpayer’s chemicals were used to form a...
View ArticleSix-Year Spread Applies to 481(a) Adjustments After Terminated S...
New temporary rules clarify a six-year spread period for Section 481(a) adjustments after an eligible terminated S corporation changes from a cash to an accrual method of accounting. These rules apply...
View ArticleFlorida Adopts Hope Scholarship Program Regulation
Florida has adopted an emergency rule for the sales and use tax credit under the Hope Scholarship Program. The credit may be used by a person that makes a contribution to an nonprofit...
View ArticleNew Jersey Provides Tax and Fee Information for Transient Accommodations Rentals
New Jersey provides information on previously enacted legislation imposing state sales tax and hotel/motel occupancy fees and assessments on charges for rentals of transient accommodations. (TAXDAY,...
View ArticleOregon High Court Rules on Use of Motor Vehicle Dealer Privilege Tax
The Supreme Court of Oregon has held that the tax imposed by Oregon Laws 2017, chapter 750, section 90 is not subject to Article IX, section 3a, of the Oregon Constitution because it is not based on...
View ArticleProposed Regs Limit Charitable Contributions Made to Avoid SALT Deduction...
An individual, estate, and trust generally must reduce the amount of any charitable contribution deduction by the amount of any state and local tax (SALT) credit he or she receives or expects to the...
View ArticleCalifornia Finds Combined Reporting Scheme Constitutional
California can force inter state unitary businesses to use combined reporting, while allowing intra state unitary businesses to pick a reporting method. This taxing scheme does not unconstitutionally...
View ArticleNorth Carolina Provides IRC §965 Reporting Guidance
North Carolina provided guidance on IRC §965 income reporting for corporate and personal income taxpayers. The guidance provides details on how to report the income on 2017 North Carolina: – C...
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