On this episode of Greenberg Traurig’s GeTtin’ SALTy podcast, host Nikki Dobay and guest John Ormonde explore recent developments involving Public Law 86-272 and the limits it may place on state income-taxing authority.
They explain the difference between Joyce and Finnigan apportionment approaches, discuss why the Massachusetts Appellate Tax Board found that the state’s Finnigan
In a significant development for nonresident investors and private equity structures, the California Office of Tax Appeals (OTA) held that gain attributable to IRC section 751(a) “hot assets,” such as unrealized receivables and inventory items, remain part of the sale of a partnership interest. As the sale of an intangible interest, the sale of partnership
Oregon’s proposed Financial Assets Tax would impose a 1% to 1.2% tax on certain taxpayers with a net worth exceeding $30 million.
Continue Reading Oregon Ballot Initiative Filed to Create Financial Assets Tax on Multimillionaires
Recent state tax decisions address the scope of P.L. 86-272, evidentiary requirements for refund claims, and the classification of income from the disposition of business assets.
Continue Reading Recent State Income Tax Decisions and Their Potential SALT Implications for Multistate Businesses
In GeTtin’ SALTy Episode 85, Nikki Dobay and Madeline Orlando discuss recent litigation involving state packaging extended producer responsibility laws and the potential implications for businesses subject to emerging EPR programs.
In GeTtin’ SALTy Episode 84, Nikki Dobay and Samantha Trencs discuss California Senate Bill 122, its expansion of sales tax to certain software and digital products, and related compliance considerations for businesses.
California’s CDTFA addressed stakeholder questions on proposed SB 122 regulations, including software and SaaS tax sourcing, MPU rules, contract transitions, and compliance ahead of the Jan. 1, 2027, effective date.
Continue Reading CDTFA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
This fall, catch Greenberg Traurig’s State and Local Tax (SALT) team on the road and online, speaking at leading tax conferences and hosting timely discussions on emerging state tax developments. From legislative and litigation updates to property tax, apportionment, and multistate planning issues, our attorneys are actively helping shape the conversation across the country. See
In GeTtin’ SALTy Episode 83, Nikki Dobay and Glenn Newman examine New York City’s pied-à-terre tax, implementation hurdles, and potential legal challenges.
In a pending precedential decision, the California Office of Tax Appeals held that gain from the sale of a beverage distribution division was not apportionable to California because the division was not part of a unitary business.
Continue Reading California Office of Tax Appeals Rejects Unitary Business Treatment for Gain from Sale of Company Division