Practice Area Blogs & Digests

Since 1959, taxpayers have been relying on a federal law—Public Law 86-272—to protect them from having to file state income tax returns in states where the taxpayers’ in-state activities are limited to just soliciting sales of tangible personal property. On August 4, 2021, the Multistate Tax Commission (MTC) member states voted 20-0 to revise the MTC’s “Statement of Information” regarding Public Law 86-272 in an attempt to eviscerate the federal law’s protections.

When is a brokerage not a brokerage? According to a recent Private Letter Ruling released by the IRS, the answer might surprise you.

Despite the relatively simple mechanics of the distribution and forgiveness of PPP loans, the taxation of both expenses paid for with PPP loan proceeds and forgiveness of the PPP loans has continued to evolve, leaving complicated rules for taxpayers to navigate.

Recently, many of our clients have received notices from the county assessor’s office that the county is conducting an “annual review” of their property for assessment purposes. How should you respond to these types of requests? It depends.

Last week, we reviewed the basics about captive insurance companies, nonadmitted insurance and the essence of the federal legislation known as the NRRA. This week, we examine what the states did to implement NRRA and how that affected, or may affect, insurance premiums paid to out-of-state captives.

We are seeing increased focus by state tax departments on nonadmitted insurance premium reporting, tax payments owed and auditing of captive insurance companies. This article is Part I of our primer on the application of the nonadmitted premium tax rules to purchases of insurance from out-of-state captives.

Construction is one of the more unique and fascinating industries when it comes to state tax. When working with clients on either sales and use tax planning or controversy matters, the sales and use tax structure facing contractors frequently prompts a number of unanticipated challenges.

A taxpayer with substantial back taxes has a few options to deal with IRS pressure to get them paid, and while an installment agreement can be a good outcome in some cases, there are many pitfalls to avoid when entering into one.

A number of lessons may be learned from representing clients in the bankruptcy filings in the retail and restaurant industries.

Bankruptcy law is changing around the world, away from the liquidation model and toward the model of corporate rescue. Additionally, these changes reflect movement toward venue competition for the business of hosting international bankruptcy cases.