Ideas & Insights

Tax planning opportunities for consideration in light of COVID-19, the resulting economic crisis, and evolving tax laws and regulations.

Taxpayer permitted alternative apportionment when calculating Michigan sourced income from the sale of an out-of-state business.

Services performed in Detroit for clients located outside the city should be sourced to Detroit for purposes of the city’s income tax.

State tax cash-flow maximization and risk minimization are available for private equity groups and their portfolio companies.

Employees working remotely due to the COVID-19 pandemic may result in income tax consequences to both the employee and the employer.

Fund management companies face difficult challenges in determining their state income tax filing obligations and apportionment rules.

Favorable classification available for retailers selling private label products and consumer products companies using contract manufacturing

New law for sourcing sales of services and intangibles effective with tax years beginning on or after Jan. 1, 2020.

Amended rules address apportionment and allocation of income from partnership interests owned by corporate partners.

Minnesota passes tax bill enacting numerous changes to the individual income tax, corporate business tax, and sales and use tax.

S-corporations doing business in California and that have NRBIGs are required to apportion those gains to California. However, taxpayers and tax ...

A number of MTC model provisions adopted including sourcing of sales other than tangible personal property and alternative apportionment.

Historically, some entities in the financial service industry could not utilize Connecticut’s “financial service company” apportionment because the...

Commissioner prohibited from applying alternative apportionment after failing to show statutory formula did not reflect Minnesota income.

For California purposes, section 382 applies on a pre-apportionment basis, RBIGs, NUBIGs, RBILs and NUBILs on a post-apportionment basis.

Lease tax ruling imposed on rental companies renting outside of Chicago violates the home rule provision of the Illinois Constitution.

50 states mean 50 sets of rules. We look at why state compliance is difficult and what you need to know when operating in multiple markets.

Private equity companies have become inundated with state income tax issues as portfolio company investments have shifted to partnerships and LLCs.

The combination of sales factor presence standards and market-based sourcing for receipts from sales of services can create significant problems.

The Missouri Supreme Court rules that title transfers for sales tax purposes when goods are shipped out-of-state F.O.B. manufacturer.