States Thinking Globally Taxation of Foreign Source Income
|
|
- Reynold Palmer
- 6 years ago
- Views:
Transcription
1 States Thinking Globally Taxation of Foreign Source Income Alysse McLoughlin McDermott Will & Emery New York, NY Beverly Luther Ameriprise Financial, Inc. Minneapolis, MN Institute for Professionals in Taxation: 2016 Income Tax Symposium Tucson, Arizona November 14, 2016
2 Alysse McLoughlin ALYSSE MCLOUGHLIN is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm's New York office. She focuses her practice on state and local tax matters, with particular skill working with financial services companies. Ms. McLoughlin was most recently the head of state tax at Barclays, where she was responsible for all state taxes, including income, franchise, sales and use, and excise tax issues. Her responsibilities included establishment of state tax return filing positions and reserves, participation in the financial statement process, and the handling of all state tax audits. She has also held positions as state tax counsel at Lehman Brothers and attorney in the chief counsel division of the Internal Revenue Service. Ms. McLoughlin received her LL.M. from New York University School of Law and her J.D. from Fordham University School of Law. She earned her B.A. from the State University of New York at Binghamton. Alysse is admitted to practice in New York and New Jersey.
3 Beverly Luther Beverly Luther ( Bev ) is Counsel for Ameriprise Financial, Inc. in Minneapolis where she practices international taxation. Her work focuses on international tax planning, withholding and reporting compliance, employee global mobility, and client document review. Bev has also worked in public accounting at Deloitte Tax LLP. Bev received her B.A. in Economics from Wellesley College, her law degree from the University of Minnesota Law School and an L.L.M. in Taxation from New York University. She is licensed to practice in Minnesota.
4 State Taxation of Foreign Commerce US Taxation of Foreign Source Income Foreign Commerce Clause and Jurisdiction Tax Base Apportionment Filing Methods Tax Haven legislation Transfer pricing adjustments Inversion Regulations OECD Base Erosion and Profits Shifting ( BEPS ) 2
5 US Taxation of Foreign Source Income Systems of Taxation: Worldwide v. Territorial International Taxing Rights origins: US Constitution, Art I, 8, Cl. 1: The Congress shall have power to lay and collect taxes... While there is no stated limit on our ability to tax foreign persons, there must be an economic allegiance to the US to justify taxation per international customs International Taxing rights in the US are based on: (1) Source of Income (2) Residence of Taxpayer 5
6 US Taxation of Foreign Source Income Various ways the US imposes tax on the income of foreign persons: Effectively Connected Income or ECI Income of a foreign person that is effectively connected with a US trade or business may be taxed in the US Withholding on payments made to foreign persons Fixed, Determinable, Annual, or Periodic payments ( FDAP ) or gross proceeds from the US to a foreign person may be subject to withholding tax in the US Distributions and Deemed Distributions to US Persons Actual distributions from a subsidiary or deemed distributions from a controlled foreign corporation will be included currently in US income 6
7 US Taxation of Foreign Source Income 7 Taxation through Presence: Effectively Connected Income or ECI of a foreign person that is engaged in a US trade or business may be taxed in the US A Foreign Person Engaged in a US Trade or Business : Regular, continuous, considerable activities Only the income that is Effectively Connected to the US Trade or Business is subject to taxation FIRPTA / Dispositions of US Real Property Interests = ECI Permanent Establishments or PE Generally: a fixed place of business through which an enterprise carries on a business such as an office, branch, or factory Activities of a dependent agent who habitually exercises the power to enter into binding contracts Services PE
8 US Taxation of Foreign Source Income Non-residents may also be taxed on their US source income through withholding Chapter 3 Foreign Withholding: Nonresidents are taxed 30% on their gross Fixed, Determinable, Annual, or Periodic ( FDAP ) income sourced within the US Chapter 4 FATCA Withholding Nonparticipating Foreign Financial Institutions are taxed 30% on their FDAP income and Gross Proceeds sourced within the US 8
9 US Taxation of Foreign Source Income Taxation through Distributions or Deemed Distribution Dividends from foreign subsidiaries to US companies are taxed in the US An Indirect Foreign Tax Credit is allowed for taxes paid on foreign income if the US taxpayer owns 10% or more of a corporation. Dividends from the foreign corporation are grossed up for the foreign taxes deemed paid by the corporation on that income ( 78 gross up) Controlled Foreign Corporations may also be deemed to distribute income that is currently taxable in the US, such as: Subpart F Income Investment in US Property Gain from sale of CFC stock ( 1248) 9
10 US Taxation of Foreign Source Income Taxation through Distributions or Deemed Distribution Subpart F Income includes: 953 Insurance Company Income Foreign Personal Holding Company Income Foreign Base Company Sales Income Foreign Base Company Services Income Boycott Income, Bribes and Kickbacks Exceptions: Same Country Exceptions, Active Financing 956 Investment in US Property A CFC s pro rata share of investment in US Property Ex: Tangible Property, Debt obligations of related US Parties Gain from sale of CFC stock ( 1248) 10
11 US Taxation of Foreign Source Income What foreign income is NOT federally taxed in the US? Undistributed Earnings of Controlled Foreign Corporations Foreign Sourced Income of Foreign Corporations States may factor undistributed earnings of CFCs into worldwide apportionment formula 11
12 Foreign Commerce Clause and Jurisdiction Treaty provisions that limit the application of federal tax to foreign corporations that have a permanent establishment in the United States do not apply to the states (unless the states voluntarily apply them) 12
13 13 Foreign Commerce Clause and Jurisdiction Four requirements of Complete Auto Transit v. Brady, 430 U.S. 274 (1977): Substantial Nexus Fairly apportioned Not discriminate against interstate commerce Fairly related to services provided by the state Plus two additional requirements from Japan Lines, Ltd. v. County of Los Angeles, 441 U.S. 434 (1981): States cannot create a substantial risk of international multiple taxation States cannot prevent federal government from speaking with one voice with regard to international relations
14 Foreign Commerce Clause and Jurisdiction States have jurisdiction to impose on corporations meeting substantial nexus standards an apportioned income tax that does not discriminate against foreign commerce Employees or property in state generally creates nexus Economic nexus: Use of intangible (e.g., patent) in state Specified amount of sales to customers in state 14
15 Foreign Commerce Clause and Jurisdiction - example Connecticut Deemed to have nexus if greater than $500,000 in receipts attributable to Connecticut sources. Legislation limits the application to foreign companies. Specifically, economic nexus provisions do not apply to a foreign corporation that has no income effectively connected with a United States trade or business. To the extent that a foreign company has income effectively connected with a United States trade or business, such company's gross income shall be its income effectively connected with its United States trade or business. 15
16 Foreign Commerce Clause and Jurisdiction U.S. Company Goods Foreign Manufacturer Foreign manufacturer sells goods to a company headquartered in NY Goods shipped via common carrier to U.S. Company s distribution centers throughout the United States Foreign manufacturer has no physical presence or solicitation activities in the U.S. Foreign manufacturer has no effectively connected income Does Foreign Manufacturer have nexus with any state? 16
17 Foreign Commerce Clause and Jurisdiction Does P.L apply to foreign commerce? Most states appear to apply P.L to foreign corporations California says: No. Dresser Industries, Inc., SBE, 82-SBE-307, June 29, 1982, reh g denied, October 26, CA Reg (c) Issues may arise if: Foreign company uses company vehicles and personnel to deliver goods Particularly if they pick up returned/damaged goods Foreign company conducts non-solicitation activities in the state (even if through third parties), such as Training on use of products Repair services Investigating credit Repossessing goods Collecting accounts 17
18 Tax Base Most states use federal taxable income as the starting point for computing state taxable income. Federal taxable income takes into account the concepts of ECI and PE where a treaty applies Without a modification, foreign corporations with no federal taxable income reported on Form 1120F arguably have no state taxable income (but may have minimum tax obligations) Some states use ECI as a starting point, but don t respect treaty exemptions Without modification, income reported on Form 1120F is generally limited to income earned in the U.S., not worldwide income 18
19 Tax Base Some states explicitly require worldwide income computations without regard to limitations on taxable income under the IRC or treaties required. No longer required in New York and possibly New Jersey when reporting on a separate company basis. 19
20 Tax Base - Dividends Federal Treatment of Dividends IRC 243 Dividend received deduction (DRD) Only applies to dividends received by a corporation (a)(1) - 70% (general rule, any corporation)(30% taxed) (a)(2) 100% (small business) (0% taxed) (a)(3) 100% (qualifying dividends) (0% taxed) No DRD allowed for dividends received from foreign corporations 20
21 Tax Base - Dividends Kraft General Foods, Inc. v. Iowa, 505 U.S. 71 (1992) Iowa based its state income tax on federal taxable income as reported under the IRC computed on a separate return basis Under the IRC, dividends from a domestic corporation were eligible for 100% Dividend Received Deduction ( DRD ) in various percentages but dividends from foreign subsidiaries were not Kraft argued that Iowa violated the Commerce Clause by discriminating against foreign commerce because the DRD was allowed for dividends paid from domestic but not foreign subsidiaries Iowa argued that the Iowa system was justified because it followed the IRC and resulted in considerable administrative efficiency in administering the tax The Court reversed the Iowa Supreme Court and held that the Iowa tax facially discriminated against foreign commerce. Blind conformity was held to be unconstitutional. 21
22 Tax Base - Dividends Critical Importance of Factor Representation States like New Hampshire and Vermont that tax foreign dividends must provide factor representation to avoid constitutional issues. Dividends are separately apportioned to allow foreign factors that generated the income to dilute the domestic apportionment fraction. However, there are a number of practical problems that must be considered: Recognition of Tiered Structures--What if the entity that pays the dividend to the water s edge group is a holding company and therefore does not have the operational factors that produced the income? Recognition of Multiple Accounting Periods--What if the entity has negative taxable income in the year the dividend is paid, or the factors have declined substantially? 22
23 Tax Base Subpart F Under Subpart F, certain taxpayers are taxed directly on income earned by certain controlled foreign corporations States generally include Subpart F income in the state tax base unless a specific exemption applies 23 Some states provide a specific deduction for Subpart F income or include Subpart F income as a dividend eligible for a dividends received deduction; California water s-edge filers include a portion of CFC s income in water s edge return The CFC s net income is multiplied by a ratio of its subpart F income for the taxable year to its earnings and profits ( E&P ) for the taxable year to arrive at the amount of CFC income that will be included in the combined Report.
24 Tax Base Subpart F Generally, IRC 1248 provides that if a taxpayer owns 10% or more of the stock of a CFC and such stock is sold, then gain attributable to the sale is treated as a dividend from the foreign corporation to the extent of the stockholder s share of the corporation s E&P IRC 1248 has the effect of converting capital gain to dividend income potentially eligible for any state DRD Most states do not modify the treatment of gains from the sale of a foreign corporation s stock mandated by 1248 Some exceptions: California does not incorporate IRC Sec Cal. Rev. & Tax. Code Alaska DRD does not apply to gain treated as a dividend for federal tax purposes under Internal Revenue Code section Alaska Admin. Code tit (h). 24
25 Tax Base Section 78 Gross Up Generally, IRC 78 provides that if a taxpayer owns 10% or more of a foreign corporation and is claiming foreign tax credits, then any dividend from that foreign corporation is grossed up for the foreign taxes deemed paid by the corporation (See IRC 902 and 960) Because states do not allow the use of the foreign tax credits, most allow the 78 gross-up portion of the dividend to be subtracted from federal taxable income MA allows only 95% to be deducted from federal taxable income 25
26 Tax Base Expense Disallowance Some states may disallow expenses associated with Subpart F income or foreign dividends The subtraction for Subpart F income may be net of expenses North Carolina provides a subtraction for Any amount included in federal taxable income under section 78 or section 951 of the Code, net of related expenses. N.C. Gen. Stat (b)(3b). Other states have a more general disallowance provision No deduction shall be allowed for any amount otherwise allowable as a deduction which is allocable to one or more classes of income not included in the measure of the tax imposed by this part, regardless of whether that income was received or accrued during the taxable year. Cal. Rev. & Tax. Cd (a). 26
27 Tax Base Expense Disallowance California case concerning expense disallowance: In Apple Inc. v. Cal. Franchise Tax Board, 199 Cal App 4 th 1 (2011), petition for rev. den., 2012 Cal. LEXIS 324 (2012), the California Court of Appeals, affirming a superior court decision, held that a state corporate income/franchise taxpayer successfully showed that its loan interest expenses were allocable to its taxed domestic earnings, rather than to its non-taxed dividends received from foreign subsidiaries, as the dominant purpose of the underlying borrowings was to fund its domestic operations. 27
28 Tax Base Related-Party Expense Disallowance Generally, a requirement to add back otherwise deductible expenses that arise as a result of certain related-company transactions, unless an exception applies, such as if the related member is subject to tax in another state Example of a typical expense disallowance provision: For purposes of computing net income under this chapter, a taxpayer shall add back otherwise deductible interest expenses and costs and intangible expenses and costs directly or indirectly paid, accrued, or incurred to, or in connection directly or indirectly with one or more direct or indirect transactions with, one or more related members. Mass. Gen. L. Ch. 63, Sec. 31I(b) 28
29 Tax Base Related-Party Expense Disallowance Treaty Exception May be part of subject to tax in another state exception Some states merely require that payee be located in a treaty country Generally, a comprehensive income tax treaty is a convention or agreement, entered into by the U.S. and approved by Congress, with a foreign government for the allocation of all categories of income subject to taxation or the withholding of tax on interest, dividends, and royalties for the prevention of double taxation of the respective nations residents and the sharing of information. See, e.g., Ga. Code. Ann (a)(1). 29
30 Apportionment - Throwback Throwback If taxpayer is not taxable in destination country, sales may be thrown back to state or origin Under the MTC, [a] taxpayer is taxable in another State if (1) in that State he is subject to a net income tax, a franchise tax measured by net income, a franchise tax for the privilege of doing business, or a corporate stock tax, or (2) that State has jurisdiction to subject the taxpayer to a net income tax regardless of whether, in fact, the State does or does not do so. State is defined to include a foreign country 30 What is the appropriate standard to determine if a foreign country has jurisdiction to subject the taxpayer to a net income tax?
31 Apportionment - Throwback Should P.L be used to determine if a taxpayer is taxable in a destination jurisdiction outside the U.S.? California does not apply P.L to foreign commerce Thus, solicitation activity in a foreign country is sufficient to create nexus and prevent throwback However, this does not apply to sale to Puerto Rico (i.e., Puerto Rico is treated as a state ) New Hampshire, on the other hand, has attempted to force companies to show greater levels of activity to prevent throwback, ranging all the way to permanent establishment! 31
32 Filing Methods Worldwide combined reporting Held constitutional in Container and Barclays Bank, but no state currently requires worldwide combined reporting without providing water s-edge election except for Alaska Water s-edge reporting Election in several states e.g., California, Idaho, Utah, Massachusetts Required in many states e.g., Illinois, Wisconsin, Michigan, Minnesota Some states exclude all foreign corporations from their unitary returns filed on a water s edge basis; however, most states still include foreign corporations under certain circumstances 32
33 Filing Methods - Foreign Entity Inclusion Some typical rules for inclusion of foreign entities: A foreign corporation may be included in a unitary return if it is subject to federal income tax or required to file a federal income tax return A foreign corporation may also be included in a unitary return to the extent of its ECI A foreign corporation with no ECI may be included in a unitary return to the extent of its U.S. source FDAP income A foreign corporation may be included in a unitary return to the extent that 20% or more of its activity is within the US Some states will look at the average of the corporation s property and payroll factors Other states look at the average of the corporation s property, payroll, and sales factors Another approach is whether the corporation has less than 80% active foreign business income 33
34 Filing Methods - Foreign Entity Inclusion A CFC may be included in a unitary return to the extent of its subpart F income In CA, a CFC is included in the unitary return based on the ratio of its subpart F income to current year E&P In WV, the income of a CFC is included to the extent of its subpart F income, but any income that was subject to an effective rate of tax in a foreign country that is greater than 90% of the maximum federal rate is excluded (i.e., high tax CFC exception) In NH, Subpart F income is asserted to be taxed as foreign dividends and given foreign factor modification 34
35 Filing Methods - Foreign Entity Inclusion A new concept is the inclusion of a foreign corporation in a unitary return if it earns more than 20% of its income, directly or indirectly, from intangible property or service related activities, the costs of which are deductible against the business income of other members of the unitary group (DC, MA, and WV) Inclusion is limited to the extent of the income and apportionment factors related to such intangible property and service related activities In DC, the provision is limited to foreign corporations that are residents of a country that does not have a comprehensive income tax treaty with the U.S. In WV, the provision does not apply to income that is exempt from federal income tax pursuant to a comprehensive income tax treaty with the U.S. 35
36 Filing Methods - Foreign Entity Inclusion A small number of states are also including a foreign corporation in the unitary return if it is incorporated or doing business in a tax haven jurisdiction (e.g., AK, DC, MT, and WV) In AK, a tax haven jurisdiction is a country that does not impose an income tax, or that imposes an income tax at a rate lower than 90% of the US rate For the AK tax haven provision to apply, the foreign corporation must either: (1) have 50% or more of its sales, purchases, or payments of income or expenses, exclusive of payments for intangible property, made directly or indirectly to one or more members of the unitary return; or (2) not conduct any significant economic activity In DC, the definition of a tax haven means a jurisdiction that may have one of statutorily enumerated traits. REPEALED NOVEMBER 2015 In MT, the list of tax haven countries is set forth by statute and is updated as necessary 36 In WV, the list of tax haven countries is based on the OECD tax haven designations
37 Filing Methods - Foreign Entity Inclusion 37 Tax Haven - Developments Recent tax haven legislative activity: Colorado (Senate Committee postponed action on May 1, 2015) Maine (Governor vetoed in 2014, and 2015 renewal efforts failed) Massachusetts (House withdrew proposed legislation on April 27, 2015) New Hampshire (House tabled bill March 11, 2015) Oregon (enacted Or. Rev. Stat , effective for tax years beginning on or after January 1, 2014) Rhode Island (enacted R.I. Gen. Laws (c)(8), (d), effective for tax years beginning on or after January 1, 2015) Connecticut (effective in 2016 Legitimate Business Purpose Exception and Income Tax Treaty Exception Lux, Ireland, Switzerland) Discussions in AL, KY, LA, NJ, CO, PA, and VT
38 Tax Haven Summary of Problems Arbitrary and Misleading Unsuitable to Address Tax Avoidance Complaints Extends State tax jurisdiction beyond National tax jurisdiction per agreed Income Tax Treaties Inconsistent with Permanent Establishment concept Foreign Nations and MNCs will withhold investment and trade A Slippery Slope to Worldwide Unitary Can include companies that are not subject to U.S. National tax reporting Creates complex administrative difficulties Need to convert local books and currencies into formats acceptable to various U.S. States Uncertainties Is Ireland, The Netherlands, or even the UK, a Tax Haven? How many more States may adopt some form of Tax Haven rules? 38
39 Transfer Pricing I.R.C. 482 Federal transfer pricing authority generally involves international pricing. Are states required to respect federal determinations? States vary as to the statutory authority granted to adjust transfer prices Comptroller of the Treasury v. Gannett Co., 741 A.2d 1130 (Md. 1999) (state found not to have transfer pricing authority) New Jersey TAM (Feb. 16, 2012) [I]n most circumstances, APAs and their content, including pricing methodologies, economic assumptions and analysis and market valuations, will be respected by the Division. 39
40 Transfer Pricing MTC Transfer Pricing Program: the MTC has formed an Arm s- Length Adjustment Service Advisory Group ( ALAS ). Some key elements: Training of staff (a transfer pricing expert has been brought on board) Secure cost-effective economic analyses of transfer pricing studies Initially from third parties Eventually by MTC staff Provide initial technical audits prior to economic analyses 40
41 Federal Inversion Rules Regs Final Regulations issued October 13, 2016 Generally: certain related party debt instruments may be reclassified as stock unless certain rules are met Impact: revolving credit agreements may turn into equity Scaled back version of original draft: Rules do not apply to foreign-issued debt and some other instances Regulations are still a work in progress Reserved sections include non-us issued intercompany loans and obligations not in debt form, downward attribution rules Two new rules: Documentation Rules Per Se Stock / Transaction Rules 41
42 Federal Inversion Rules Regs Documentation Rules Introduces new documentation requirements to the debt/equity analysis of related party debt instruments. Applies to debt instruments issued by a US corporation to members of its Expanded Group, which is generally corporations affiliated by 80% common vote or value. Failure to meet rules will generally treat debt as stock for US federal income tax purposes Required Documentation for Debt Agreements: Legally binding obligation to pay a certain sum Creditor Rights Reasonable Expectation of Payment Proof of Debtor/Creditor Relationship Exemptions and Safe Harbors: Excepted Regulated Financial Companies and Regulated Insurance Companies Cash Pooling Agreements 42
43 Federal Inversion Rules Regs Per Se Stock / Transaction Rules Debt obligations will be treated as stock if issued by a US Corporation to a member of its Expanded Group and either: The debt instrument was issued in certain General Rule Transactions, or The US corporation engages in certain Funding Rule Transactions during the 3- years before or after the debt issuance General Rule Transactions: issuance of a note by a US Corp: And distributes its own note to a non-us parent In exchange for stock of a non-us parent In certain asset reorganizations where the instrument is received as boot Funding Rule Transactions: if the US Corp debt issuer: Makes a distribution of cash or property to its non-us parent Acquires stock from its Expanded Group Distributes the debt instrument to an Expanded Group member as boot in an asset reorganization Exceptions: Qualified Short-Term Debt Instruments 43
44 Federal Inversion Rules Regs What should your company do next about new 385 Regs? Identify Debt Instruments that could be subject to the Documentation and Per Se Stock Rules Review existing agreements for compliance with the Regulations Develop procedures to ensure future debt instruments will comply with Regulations 44
45 OECD BEPS Framework Organization for Economic Cooperation and Development = OECD Base Erosion Profit Shifting = BEPS The BEPS Framework is aimed at tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity. Requirements are being passed at individual country level per recommendation of OECD 45
46 OECD BEPS Action Items Action 1: Digital Economy Action 2: Hybrid Mismatch Arrangements Action 3: Controlled Foreign Company Rules Action 4: Interest Deductions Action 5: Harmful Tax Practices Action 6: Preventing Treaty Abuse Action 7: PE Rules Action 8 10: Transfer Pricing Action 11: Measuring and Monitoring BEPS Action 12: Mandatory Disclosure Rules Action 13: Transfer Pricing Documentation and Country-By- Country Reporting Action 14: Solving Treaty Disputes 46 Action 15: Bilateral Treaty Instrument
47 OECD BEPS Action Items Action 7: PE Rules Prevent avoidance of PE via Commissionaire arrangements Re-think the Preparatory or Auxillary exception for PE Determination Action 13: Transfer Pricing Documentation and Country-By-Country Reporting 3-tier approach to Global Transfer Pricing Reporting Master File Local File Country-by-Country Reporting or CbCR 47
48 OECD BEPS Action 13 Items Master File High level information regarding the company s global business operations and transfer pricing policies Local File Specific to each country, identifying material related party transactions, amounts involved in those transactions, and the company s analysis of the transfer pricing determinations they have made with regard to those transactions CbCR For each tax jurisdiction a MNE does business, provide a report of the amount of revenue, profit before income tax, and income tax paid and accrued, number of employees, stated capital, retained earnings, and tangible assets in each jurisdiction. Identify each entity within the group doing business in a particular tax jurisdiction and to provide an indication of the business 48 activities each entity engages in.
49 Conclusion Taxation of Foreign Source Income will continue to be an issue of growing importance. International Reach of Corporations Due to Open Markets and Technology Need for revenue and perception of tax avoidance States are increasingly aggressive but states have widely disparate statutes that offer pitfalls and opportunities. To the extent that federal tax reform becomes a reality, careful planning must be done regarding repatriation of earnings. 49
Transfer Pricing Implications for State & Local Tax
Transfer Pricing Implications for State & Local Tax G I A N LU CA P I T ET T I K P M G K E I T H R O B I NSON, P H D P WC I N S T I T U T E F O R P R O F E S S I O N A L S I N TA X AT I O N 2 0 1 6 I N
More informationThe 2019 National Multistate Tax Symposium State tax reboot The age of Multistate. February 6-8, 2019
The 2019 National Multistate Tax Symposium State tax reboot The age of Multistate February 6-8, 2019 State treatment of federal Tax Cuts and Jobs Act s foreign income and GILTI Susan Courson-Smith, Pfizer
More informationFederal Tax Reform Impact on 2019 Legislative Sessions: GILTI
Federal Tax Reform Impact on 2019 Legislative Sessions: GILTI Executive Committee Task Force on State and Local Taxation Scottsdale, Arizona November 17, 2018 Karl Frieden, COST Deborah Bierbaum, AT&T
More informationState Tax Implications of International Tax Reform
State Tax Implications of International Tax Reform NCSL Executive Task Force on State & Local Taxation Presenters: March 23, 2018 Scott Roberti, Ernst & Young, LLP (Moderator) Karl Frieden, COST Michael
More informationNexus Assistant Results
Nexus Assistant Results Tax Type: Corporate Income Legend: N/A - Not Applicable Alabama --Company Business income includes income from intangible personal property, the acquisition, management, and disposition
More informationTop Ten Nonconformity Issues Between Federal and State
Top Ten Nonconformity Issues Between Federal and State Sixth Annual UW-TEI Tax Forum February 17, 2017 Jeff Friedman, Partner Michele Borens, Partner 2017 (US) LLP All Rights Reserved. This communication
More informationSB 28 Joyce to Finnigan
SB 28 Joyce to Finnigan Senate Committee on Finance and Revenue February 6, 2017 2 What is it? Joyce and Finnigan are references to two different ways of calculating a unitary group s sales factor numerator
More informationState responses to tax reform
State responses to tax reform Federal tax reform- an overview H.R. 1 signed into law December 22, 2017 Included elements of the House and Senate versions of the bills - Not many surprises in conference
More informationWorkshop K. International Companies with U.S. Activities Multistate Considerations for Inbound Companies
28th Annual Tuesday & Wednesday, January 29 30, 2019 Hya Regency Columbus, Columbus, Ohio Workshop K International Companies with U.S. Activities Multistate Considerations for Inbound Companies Tuesday,
More informationIRC 965, BEAT, GILTI and FDII Through the Lens of a SALT Professional + Recent Developments
IRC 965, BEAT, GILTI and FDII Through the Lens of a SALT Professional + Recent Developments June 21, 2018 Korwin Roskos (Moderator) Senior Tax Manager-State & Local Tax, Amazon Vice Chair of TEI s SALT
More informationPARTNERSHIP AUDIT REGULATIONS The Great Unknown
2018 FTA Annual Meeting June 3 6, 2018 Nashville, TN PARTNERSHIP AUDIT REGULATIONS The Great Unknown Nikki Dobay, Senior Tax Counsel, Council On State Taxation Helen Hecht, General Counsel, Multistate
More informationE-Commerce, Nexus, and State Policy Trends. LeAnn Luna. 7 th Annual Tax Policy Conference May 20, 2010
E-Commerce, Nexus, and State Policy Trends LeAnn Luna University of Tennessee Prepared for the New Mexico Tax Research Institute epa ed o t e e e co a esea c st tute 7 th Annual Tax Policy Conference May
More informationModel Regulation Service July 1996
Model Regulation Service July 1996.MODEL INDEMNITY CONTRACTS ACT Editor s Note: These laws are generally referred to as Reciprocal Insurance or Inter-Insurance. Table of Contents Section 1. Section 2.
More informationConformity Issues in SALT
Carley Roberts, Partner Zachary Atkins, Associate TEI Nashville 2014 Spring Seminar Franklin, TN May 14, 2014 Conformity Issues in SALT Agenda Conformity and the State Income Tax Base Capital Gains Conformity
More informationThe 2019 National Multistate Tax Symposium State tax reboot The age of Multistate. February 6-8, 2019
The 2019 National Multistate Tax Symposium State tax reboot The age of Multistate February 6-8, 2019 Sales factor deep dive Defining today s Market Sheelagh Beaulieu, CVS Caremark Corporation Craig B.
More informationState and Local Tax Update. Tuesday, November 28, 2017 Wichita Country Club Tim Hartley - Director
State and Local Tax Update Tuesday, November 28, 2017 Wichita Country Club Tim Hartley - Director Presenters Tim Hartley Director Tax tim.hartley@us.gt.com 316 636 6507 Grant Thornton LLP. All rights reserved.
More informationMultistate Income Tax
Multistate Income Tax Marion Kopin, CPA Kopin & Company, CPA, PC mkopin@kopincpa.com Multistate Income Taxation Overview Forty-seven states and the District of Columbia impose some type of income or franchise
More informationTHE STATE TAXES MINEFIELD
THE STATE TAXES MINEFIELD State Tax Planning for the Small Flight Department by Joanne Barbera and Heidi Albers You men and women who operate this nation s small flight departments are among the busiest
More informationThe State Taxation of Foreign Source Income: Planning, Compliance, and Constitutional Challenges Post-Federal Tax Reform
The State Taxation of Foreign Source Income: Planning, Compliance, and Constitutional Challenges Post-Federal Tax Reform PRESENTERS: ALYSSE MCLOUGHLIN, MCDERMOTT WILL & EMERY, NEW YORK, NY JEFFREY VESELY,
More informationAdd-Back Statutes: Where Do We Go From Here?
2005 SEATA Conference July 12, 2005 Add-Back Statutes: Where Do We Go From Here? Presented By: Joe Garrett, Esq. Alabama Department of Revenue & Kelly W. Smith, CPA, Esq. PricewaterhouseCoopers LLP 0 Related
More informationNEW YORK STATE BAR ASSOCIATION TAX SECTION. Annual Meeting. State and Local Tax Implications of Federal Tax Reform.
NEW YORK STATE BAR ASSOCIATION TAX SECTION Annual Meeting State and Local Tax Implications of Federal Tax Reform January 23, 2018 Chair: Irwin M. Slomka, Morrison & Foerster LLP, New York City Joshua E.
More informationSTATE APPORTIONMENT UPDATE
STATE APPORTIONMENT UPDATE Sourcing of Services and Market-based Souring Laura Holmes Senior Director BDO USA February 16, 2016 TEI Houston Chapter Tax School Laura Holmes, CPA State and Local Tax Senior
More informationFederal Tax Reform How Have the States Reacted So Far?
Federal Tax Reform How Have the States Reacted So Far? 2018 MSATA Annual Meeting Kansas City, Missouri August 21, 2018 Karl Frieden, COST Helen Hecht, MTC Alysse McLoughlin, McDermott, Will & Emery Agenda
More informationWhirlwind Review of New State Tax Laws
Todd Lard, Partner Sutherland Asbill & Brennan LLP Carley Roberts, Partner Sutherland Asbill & Brennan LLP FTA Annual Conference June 10, 2014 Whirlwind Review of New State Tax Laws Agenda Factor Weighting
More informationNEW JERSEY DIVISION OF TAXATION REGULATORY SERVICES BRANCH TECHNICAL BULLETIN
NEW JERSEY DIVISION OF TAXATION REGULATORY SERVICES BRANCH TECHNICAL BULLETIN TB - 80 ISSUED: 3-15-17 TAX: TOPIC: CORPORATION BUSINESS TAX ADDBACK OF OTHER STATES TAXES The Corporation Business Tax Act
More informationTWIST-Q Summary of developments
TWIST-Q Summary of developments Rate changes Impact The corporate income tax rate is increased to 7.0 percent effective July 1, 2017. Senate Bill 9 (veto overridden July 6, 2017). IL Because the state
More informationTWIST-Q Summary of developments First Quarter 2019
TWIST-Q Summary of developments First Quarter 2019 This checklist includes developments for Quarter 1 of 2019 that have occurred prior to the date of publication. Please note that certain Quarter 1 items
More informationTECHNICAL EXPLANATION OF THE SENATE COMMITTEE ON FINANCE CHAIRMAN S STAFF DISCUSSION DRAFT OF PROVISIONS TO REFORM INTERNATIONAL BUSINESS TAXATION
TECHNICAL EXPLANATION OF THE SENATE COMMITTEE ON FINANCE CHAIRMAN S STAFF DISCUSSION DRAFT OF PROVISIONS TO REFORM INTERNATIONAL BUSINESS TAXATION Prepared by the Staff of the JOINT COMMITTEE ON TAXATION
More informationImpact of Federal Reform on State Corporate Income Tax Base & the Best and Worst of Sales Tax Administration Focus on New Mexico
Council On State Taxation 1 2018 15 th Annual NMTRI Tax Policy Conference Impact of Federal Reform on State Corporate Income Tax Base & the Best and Worst of Sales Tax Administration Focus on New Mexico
More informationState Responses to TCJA s International Provisions
State Responses to TCJA s International Provisions Helen Hecht, General Counsel, Multistate Tax Commission Shirley Sicilian, National Director State and Local Tax Controversy, KPMG Alysse McLoughlin, Partner,
More informationSENATE TAX REFORM PROPOSAL INTERNATIONAL
The following chart sets forth some of the international tax provisions in the Senate Finance Committee s version of the Tax Cuts and Jobs Act bill, as approved by the Senate Finance Committee on November
More informationFinal Section 385 Regs: Navigating State and Local Tax Impact of New Debt-to-Equity Reclassification Rules
FOR LIVE PROGRAM ONLY Final Section 385 Regs: Navigating State and Local Tax Impact of New Debt-to-Equity Reclassification Rules THURSDAY, JANUARY 12, 2017, 1:00-2:50 pm Eastern IMPORTANT INFORMATION FOR
More informationU.S. Tax Legislation Corporate and International Provisions. Corporate Law Provisions
U.S. Tax Legislation Corporate and International Provisions On December 20, 2017, Congress enacted comprehensive tax legislation (the Act ). This memorandum highlights some of the important provisions
More informationA BILL IN THE COUNCIL OF DISTRICT OF COLUMBIA
A BILL IN THE COUNCIL OF DISTRICT OF COLUMBIA To amend Title 47, Chapter 18 of the District of Columbia Official Code by adding thereto new sections, designated 47-1805.02A, 47-1810.04, 47-1810.05, 47-1810.06,
More informationUnderstanding Oregon s Throwback Rule for Apportioning Corporate Income
Understanding Oregon s Throwback Rule for Apportioning Corporate Income Senate Interim Committee on Finance and Revenue January 12, 2018 2 Apportioning Corporate Income Apportionment is a method of dividing
More informationModel Regulation Service April 2000 UNIFORM DEPOSIT LAW
Model Regulation Service April 2000 Table of Contents Section 1. Section 2. Section 3. Section 4. Section 5. Section 6. Section 7. Section 8. Section 9. Section 10. Section 1. Definitions Deposit Requirement
More informationThe OECD s 3 Major Tax Initiatives
The OECD s 3 Major Tax Initiatives 1. The Global Forum on Transparency and Exchange of Information for Tax Purposes Peer review of ~ 100 countries International standard for transparency and exchange of
More informationU.S. Tax Seminar Updates & Developments November 2013
Updates & Developments Ron Mazurik, Senior Tax Manager Alon Sherer, Senior Tax Manager Agenda Recent Legislation Recent Cases Proposed Legislation Points for Attention State Tax Developments 2 Recent Tax
More informationUnited States Tax Alert
International Tax United States Tax Alert 6 February 2015 On February 2, 2015, the Obama Administration (the Administration) released its FY2016 Budget and the Treasury Department released the General
More informationState Tax After TCJA: Treatment Of International Income
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com State Tax After TCJA: Treatment Of International
More informationFundamentals and Best Practices for Handling Multistate Taxation Presented Thursday, April 16, 2015
1 Fundamentals and Best Practices for Handling Multistate Taxation Presented Thursday, April 16, 2015 2 Housekeeping 3 Credit Questions Today s topic Speaker To earn RCH credit you must 4 Stay on the webinar,
More informationFinal Paycheck Laws by State
ALABAMA AL No Provision No Provision ALASKA AK 23.05.140(b) ARIZONA AZ Ariz. Rev. Stat. 23-350, 23-353 ARKANSAS AR Ark. Code Ann. 11-4-405 CALIFORNIA CA Cal. Lab. Code 201 to 202, 227.3 COLORADO CO Colo.
More informationBEPS Beyond Fortune 1000 October Armanino LLP amllp.com Armanino LLP amllp.com
BEPS Beyond Fortune 1000 October 2016 1 Armanino LLP amllp.com Armanino LLP amllp.com 1 BEPS Overview Timeline Pre-2013 - Organization for Economic Cooperation and Development (OECD) concern that existing
More informationThe 2018 National Multistate Tax Symposium Take the lead Tax reform and fortifying state positions. February 7-9, 2018
The 2018 National Multistate Tax Symposium Take the lead Tax reform and fortifying state positions February 7-9, 2018 Planning for future-state taxation regimes And the future state Scott Schiefelbein,
More informationHold the Intercompany Transactions State and Local Tax Considerations
Hold the Intercompany Transactions State and Local Tax Considerations Current Issues in State & Local Taxation TEI Philadelphia Chapter February 22, 2017 Open Weaver Banks Andrew Appleby 2017 (US) LLP
More informationTax Management. 1 Steven C. Wrappe, Erin Collins, and Cameron Teheri, It
Tax Management Transfer Pricing Report Reproduced with permission from Tax Management Transfer Pricing Report, Vol. 23 No. 16, 12/11/2014. Copyright 2014 by The Bureau of National Affairs, Inc. (800-372-1033)
More informationVARIABLE CONTRACT MODEL LAW
Model Regulation Service April 1999 Table of Contents Section 1. Section 2. Section 3. Section 4. Section 5. Section 6. Section 1. Domestic Companies Contract Statement Required License Required Power
More informationSENATE TAX REFORM PROPOSAL INTERNATIONAL
The following chart sets forth some of the international tax provisions in the Senate s version of the Tax Cuts and Jobs Act, as approved by the Senate on December 2, 2017. This chart highlights only some
More informationSTOCKHOLDERS INFORMATION SUPPLEMENT SCHEDULE SIS
Model Regulation Service April 2001 STOCKHOLDERS INFORMATION SUPPLEMENT SCHEDULE SIS Table of Contents Section 1. Section 2. Section 3. Section 4. Section 5. Section 1. General Instructions Financial Reporting
More informationChairman Camp s Discussion Draft of Tax Reform Act of 2014 and President Obama s Fiscal Year 2015 Revenue Proposals
Chairman Camp s Discussion Draft of Tax Reform Act of 2014 and President Obama s Fiscal Year 2015 Proposals Relating to International Taxation SUMMARY On February 26, 2014, Ways and Means Committee Chairman
More informationAge of Insured Discount
A discount may apply based on the age of the insured. The age of each insured shall be calculated as the policyholder s age as of the last day of the calendar year. The age of the named insured in the
More informationAlternative Apportionment - The Process and the Impact
Alternative Apportionment - The Process and the Impact Current Issues in State & Local Taxation TEI Philadelphia Chapter February 22, 2017 Maria Todorova Open Weaver Banks 2017 (US) LLP All Rights Reserved.
More informationCALIFORNIA UPDATE. Financial Institutions State Tax Coalition Annual Meeting November 12, Jeffrey M. Vesely Pillsbury Winthrop Shaw Pittman LLP
CALIFORNIA UPDATE Financial Institutions State Tax Coalition Annual Meeting November 12, 2018 Jeffrey M. Vesely Pillsbury Winthrop Shaw Pittman LLP 4834-0357-6954v1 AGENDA FEDERAL TAX REFORM APPORTIONMENT
More informationA Look At State Income Tax Issues and Consequences of the Administration s Proposed International Tax Revisions
A Look At State Income Tax Issues and Consequences of the Administration s Proposed International Tax Revisions By George Barry, Director, Deloitte Tax LLP A TAX MANAGEMENT WEEKLY STATE TAX REPORT! July
More informationState Tax Implications of Federal Tax Reform
State Tax Implications of Federal Tax Reform Todd Lard, Partner Todd Betor, Associate 2018 (US) LLP All Rights Reserved. This communication is for general informational purposes only and is not intended
More informationState Tax Chart Results
State Tax Chart Results Tax Type: Sales/Use Legend: N/A - Not Applicable Software as a Service (SaaS) This chart shows whether or not the state imposes a tax on the sales of Software as a Service (SaaS).
More informationAMERICAN JOBS CREATION ACT OF 2004
AMERICAN JOBS CREATION ACT OF 2004 OCTOBER 26, 2004 TABLE OF CONTENTS Page REPEAL OF EXCLUSION FOR EXTRATERRITORIAL INCOME AND DEDUCTIONS FOR DOMESTIC PRODUCTION ACTIVITIES... 1 TAX SHELTERS... 2 Information
More informationNCSL Midwest States Fiscal Leaders Forum. March 10, 2017
NCSL Midwest States Fiscal Leaders Forum March 10, 2017 Public Pensions: 50-State Overview David Draine, Senior Officer Public Sector Retirement Systems Project The Pew Charitable Trusts More than 40 active,
More informationSTATE TAX WITHHOLDING GUIDELINES
STATE TAX WITHHOLDING GUIDELINES ( Guardian Insurance & Annuity Company, Inc. and Guardian Life Insurance Company of America (hereafter collectively referred to as Company )) (Last Updated 11/2/215) state
More informationSales Factors Based on the Benefit Received
Sales Factors Based on the Benefit Received ABA Tax Section Meeting San Diego, CA February 17, 2012 Giles Sutton, Partner Grant Thornton Robert Mahon, Partner Perkins Coie LLP 704.632.6885 206.359.6260
More informationMODEL REGULATION ON UNFAIR DISCRIMINATION IN LIFE AND HEALTH INSURANCE ON THE BASIS OF PHYSICAL OR MENTAL IMPAIRMENT
Table of Contents Model Regulation Service June 1979 MODEL REGULATION ON UNFAIR DISCRIMINATION IN LIFE AND HEALTH INSURANCE Section 1. Section 2. Section 3. Section 1. Authority Purpose Unfairly Discriminatory
More information2018 NAFC ANNUAL CONFERENCE. THE CHANGING FINANCIAL LANDSCAPE IN TRUCKING: addressing opportunities and challenges
2018 NAFC ANNUAL CONFERENCE THE CHANGING FINANCIAL LANDSCAPE IN TRUCKING: addressing opportunities and challenges State Income Tax Update Agenda State Impacts of Federal Reform State Nexus Apportionment
More informationState Tax Implications of New (and Pending) Federal Rules
Todd A. Lard Andrew D. Appleby NESTOA September 27, 2016 State Tax Implications of New (and Pending) Federal Rules All Rights Reserved. This communication is for general informational purposes only and
More informationKathryn M. Jaques Summer Tax Institute June 2017
Kathryn M. Jaques Summer Tax Institute June 2017 } General partnership } Limited partnership } Limited liability partnership (LLP) } Limited liability company (LLC) Multiple member LLC Single member LLC
More informationSTATE MOTOR FUEL TAX INCREASES:
Since 2013, 26 states have increased or adjusted taxes on motor fuel to support needed transportation investments. Twenty-three of those states increased their state gas tax, while three states Kentucky,
More informationGUIDELINES ON CORPORATE OWNED LIFE INSURANCE
Model Regulation Service April 2005 Corporate Owned Life Insurance (COLI) is life insurance a corporate employer buys covering one or more employees. With COLI, the employer is generally the applicant,
More informationAmerican Memorial Contract
American Memorial Contract Please complete all pages of the contract and send it back to Stephens- Matthews with a copy of each state license you choose to appoint in. You are required to submit with the
More informationState Income Tax Traps for Owners of Distressed Debt
State Income Tax Traps for Owners of Distressed Debt BY PARRISH IVY, SENIOR MANAGER, DELOITTE TAX LLP State Income Tax Traps for Owners Of Distressed Debt by Parrish Ivy Parrish Ivy is a senior manager
More informationTask Force on State and Local Taxation
NCSL: Executive Committee Task Force on State and Local Taxation State Implications of Federal Tax Reform Business Tax Reform (Panel 2) March 23, 2018 Presenters Andrew Phillips Quantitative Economics
More informationInternational tax implications of US tax reform
Arm s Length Standard Global views within reach. International tax implications of US tax reform Congress has approved and President Trump has signed into law a massive tax reform package that lowers tax
More informationSTATE AND LOCAL TAX IPT ANNUAL CONFERENCE. Eran Liron. Arthur J. Parham
STATE AND LOCAL IPT ANNUAL CONFERENCE TAX Eran Liron State and Local Tax Partner PricewaterhouseCoopers, LLP San Jose, CA Eran.J.Liron@us.pwc.com Arthur J. Parham General Tax Advisor Entergy Services,
More informationACORD Forms in ebixasp (03/2004)
ACORD Forms in ebixasp (03/2004) Form number Form Name Edition Date 1 Property Loss Notice 2002/1 2 Automobile Loss Notice 2002/1 3 General Liability Notice of Occurrence/Claim 2002/1 4 Workers Compensation
More information2017 Tax Reform: Checkpoint Special Study on foreign income, foreign persons tax changes in the "Tax Cuts and Jobs Act"
2017 Tax Reform: Checkpoint Special Study on foreign income, foreign persons tax changes in the "Tax Cuts and Jobs Act" On December 15, the Conference Committee-having reconciled and merged the differing
More informationMcGuireWoods State Death Tax Chart. Revised January 3, 2012
McGuireWoods Chart Revised January 3, 2012 This chart is maintained for the McGuireWoods LLP Website and is updated regularly. Any comments on the chart or new developments that should be reflected on
More informationSelf Procurement taxes
Self Procurement taxes Daniel J. Kusaila, Tax Partner Crowe Horwath LLP Audit Tax Advisory Risk Performance 2015 Crowe Horwath LLP Agenda What is a procurement tax Nexus standards and Todd Shipyards Non
More informationSTATE MOTOR FUEL TAX INCREASES:
STATE MOTOR FUEL TAX INCREASES: 2013-2018 Since 2013, 27 states have increased or adjusted taxes on motor fuel to support needed transportation investments. Twenty-four of those states increased their
More informationPROPOSED REGULATION 830 CMR
830 CMR: DEPARTMENT OF REVENUE PROPOSED REGULATION 830 CMR 63.38.1 830 CMR 63:00: TAXATION OF CORPORATIONS 830 CMR 63.38.1 is repealed and replaced with the following: 830 CMR 63.38.1: Apportionment of
More informationHouse and Senate tax reform proposals could significantly impact US international tax rules
from International Tax Services House and Senate tax reform proposals could significantly impact US international tax rules November 28, 2017 In brief The House of Representatives passed the Tax Cuts and
More informationFederal Tax Reform & the States. The Big Picture. Status Update in the States
Federal Tax Reform & the States The Big Picture Status Update in the States Introductions Panelists Liz Malm Nathan Rigney Steve Kranz Karl Frieden MultiState Associates H&R Block McDermott WIll & Emery
More informationMcGuireWoods LLP. State Death Tax Chart. Revised August 31, 2015
McGuireWoods LLP Chart Revised August 31, 2015 This chart is maintained for the McGuireWoods LLP Website and is updated regularly. Any comments on the chart or new developments that should be reflected
More informationNASRA Issue Brief: Employee Contributions to Public Pension Plans
NASRA Issue Brief: Employee Contributions to Public Pension Plans September 2017 Unlike in the private sector, nearly all employees of state and local government are required to share in the cost of their
More informationThe Impact of Joyce & Finnigan on Multi-State Combined Groups with Intangible Sales
The Impact of Joyce & Finnigan on Multi-State Combined Groups with Intangible Sales By Selena Walker I. INTRODUCTION The California State Board of Equalization decisions of In the Matter of the Appeal
More informationState and Local Taxation Update: Information Sharing and Transparency
Jeffrey A. Friedman, Partner Michele Borens, Partner May 14, 2014 TEI Denver Chapter State and Local Taxation Update: Information Sharing and Transparency Agenda Transparency in State Taxation What Type
More informationState and Local Tax Update
State and Local Tax Update State Income Tax & Sales Tax Considerations Unclaimed Property: A Compliance Overview Discussion topics Tax Cuts and Jobs Act effect on state and local taxes Other recent state
More informationInstallment Loans CHARTS. No cap other than unconscionability:
NCLC NATIONAL CONSUMER LAW CENTER Installment Loans WILL STATES PROTECT BORROWERS FROM A NEW WAVE OF PREDATORY LENDING? Copyright 2015, National Consumer Law Center, Inc. CHARTS CHART 1 Full APRs Allowed
More informationACORD Forms Updated in AMS R1
ACORD Forms Updated in AMS360 2017 R1 The following forms will use the ACORD form viewer, also new in this release. Forms with an indicate they were added because of requests in the Product Enhancement
More informationInternational Tax Update. Friday, December 1, 2017 Grant Thornton's Year End taxguide Event Brandon Joseph Senior Manager, International Tax
International Tax Update Friday, December 1, 2017 Grant Thornton's Year End taxguide Event Brandon Joseph Senior Manager, International Tax Presenters Brandon Joseph Senior Manager International Tax Services
More informationWhat Nexus Standard Would the Bill Require to Impose an Income Tax?
All States Income Tax Nexus Legislation Introduced in Congress November 2018 A bill introduced in the U.S. House of Representatives would: establish a federal physical presence nexus standard for state
More information24 th Annual Health Sciences Tax Conference
24 th Annual Health Sciences Tax Conference What s shaking? State and local tax hot topics for the life sciences industry December 8, 2014 Disclaimer EY refers to the global organization, and may refer
More informationSALES TAX AND WAYFAIR -
SALES TAX AND WAYFAIR - WHAT DOES IT MEAN FOR YOUR BUSINESS? by Karen Poist, CPA On June 21, 2018, the Supreme Court issued its decision on the South Dakota v. Wayfair, Inc. case (Wayfair). This is the
More informationTWIST-Q Summary of Developments First Quarter 2018
TWIST-Q Summary of Developments First Quarter 2018 This checklist includes developments for Quarter 1 of 2018 that have occurred prior to the date of publication. Please note that certain Quarter 1 items
More informationChanges Abound in New Tax Bill for Multinational Companies
News Changes Abound in New Tax Bill for Multinational Companies 01.08.2018 Perhaps some of the most extensive changes in H.R. 1, known as the Tax Cuts and Jobs Act (the Act ), deal with the taxation of
More informationUNIFORM SALES & USE TAX CERTIFICATE
UNIFORM SALES & USE TAX CERTIFICATE The issuer and the recipient have the responsibility of determining the proper use of this certificate under applicable laws in each state, as these may change from
More informationColorado Out of State Retailers Must Begin Collecting Sales Tax Soon
September 2018 Colorado Out of State Retailers Must Begin Collecting Sales Tax Soon Out of state retailers must collect sales tax if they meet Colorado s economic nexus requirements. Collection requirements
More informationProtection Against Abusive Interest Rates for Small Dollar Loan Products 50-State Detail (Scorecard based on data as of 1/15/08)
Protection Against Abusive Interest Rates for Small Dollar Loan Products 50-State Detail (Scorecard based on data as of 1/15/08) Alaska State Performance Category APR Comment $250, 2-week payday 443 $500,
More informationProposed revisions to US tax code would significantly impact inbound companies
from International Tax Services Proposed revisions to US tax code would significantly impact inbound companies November 28, 2017 In brief On November 17, 2016 the House of Representatives passed the Tax
More informationFinancing Unemployment Benefits in Today s Tough Economic Times
Financing Unemployment Benefits in Today s Tough Economic Times Maurice Emsellem 7 th Annual Workers Voice State Legislative Issues Conference July 19, 2003. Today s Funding Situation The Good, the Bad
More informationUniversity of Wisconsin System SFS Business Process AP /1042s/Tax Bolt-On
Contents 1099/1042-S Tax Bolt-On Process Overview... 1 Process Detail... 2 I. Search/Update for Existing Value 1099 / 1042 Records on the Bolt-On table... 2 II. Enter a New 1099/1042s records into the
More informationNAVIGATING US TAX REFORM:
NAVIGATING US TAX REFORM: WHAT BUSINESSES NEED TO KNOW State and Local Tax Implications January 17, 2018 Presenters: 2018 Morgan, Lewis & Bockius LLP Donald-Bruce Abrams, Partner Daniel Dixon, Of Counsel
More informationLong-Term Care Partnership Overview & Training Requirements Guide
Long-Term Care Insurance Mutual of Omaha Insurance Company SM Long-Term Care Partnership Overview & Training Requirements Guide 75014 Version November 16, 2015 For producer use only. Not for use with the
More information