In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more
I discussed Texas franchise tax nexus in a prior post, which can be found here. However, there is a different (albeit similar) set of rules for Texas sales and use tax nexus. As with Texas franchise tax nexus, a business...more
In my most recent blog post, I finished going through the process for computing a taxable entity’s Texas Franchise Tax responsibility. That post can be found here. However, at the end of that post, I noted that there were...more
Step 1 – Taxable Margin Once you’ve determined that your business is subject to the Texas Franchise Tax, the next step will be to compute the amount of that tax. Easy, right?...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
The Illinois Franchise Tax (the “Franchise Tax”) is an extremely complex tax that places unique burdens on corporations conducting business in Illinois. Based on our experience, many corporations incorrectly calculate their...more
The importance of calculating your Franchise Tax Allocation Factor cannot be understated. Improper calculation of this factor can lead to over and underpayment of Franchise Tax, triggering penalties, interest accrual, and the...more
This series of articles is intended to provide a deep dive into the Illinois State Franchise Tax (the “Franchise Tax”) and should be read sequentially to be best understood. The first article covered the businesses and...more
The Tennessee Department of Revenue (Department) recently posted certain selected informal conference summaries which provides taxpayers with insight into how the Hearing Office will address various issues arising under...more
An investment management company subject to California corporate franchise tax was required to source its receipts from the provision of management, administrative, and distribution services furnished to mutual funds based on...more
Texas, famously, does not tax individuals’ income, but it does impose franchise taxes on “taxable entities”, such as limited liability companies. Federal tax law treats them as partnerships unless they elect to be treated...more
Howdy folks, and welcome back to another edition of the Texas Tax Roundup, where we gab about all things Texas tax and perhaps even some things Texas tax adjacent. As ole T.S. once put it, “April is the cruelest...more
The failure of a taxable entity to file Texas franchise tax reports or pay franchise tax when due can have serious consequences, including loss of the ability of the entity to sue or defend itself in court and liability of...more
Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more
Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more
Howdy folks, and welcome back to another captivating installment of Texas Tax Roundup, where we gab about all things Texas taxes. Nothing court-side this month, just a bunch at the administrative level. Still, it’s...more
Howdy y’all! Has it been a month already? We’ve got another action-packed month of Comptroller-related news. Here we go! Court Cases Courts of Appeals Hegar v. Black, Mann, and Graham, L.L.P., No. 03-20-00391-CV (Tex....more
On March 25, the Texas Supreme Court issued a highly-anticipated decision concerning the proper test to source receipts from services for purposes of Texas franchise tax. By statute, receipts from a “service performed in this...more
In mid-January, the Texas Comptroller issued controversial amendments to its franchise (margin) tax apportionment sourcing rules. Are the rules an administrative drift towards market-based sourcing? Matt Hunsaker breaks down...more
As previously announced, the Illinois Department of Revenue has begun a new amnesty program, running October 1 through November 15, 2019. All taxes paid to the Illinois Department of Revenue for taxable periods ending after...more
On June 5, 2019, Illinois Governor J.B. Pritzker signed a $40 billion state budget bill into law. Among the various provisions included in the over 300 page budget is a provision providing for the phase-out of Illinois’...more
On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more
The Minnesota Department of Revenue issued its position on foreign disregarded entities of corporate taxpayers on October 4, 2017. In response to the Minnesota Supreme Court decision filed August 2, 2017 in Ashland Inc. v....more
On March 23, 2016, the Tennessee Supreme Court issued its much-awaited decision in the case of Vodafone Americas Holdings, Inc. et al. vs. Tennessee Commissioner of Revenue....more