On May 31, 2025, the Illinois General Assembly passed HB2755 as part of the FY2026 budget bill, which contains a number of significant tax changes to the Illinois Income Tax Act and other taxes. Governor Pritzker appears set to sign the budget before July 1st. Major changes made by HB2755 include: (1) expanding the corporate income tax base with provisions specifically targeting multinational corporations, (2) expanding the Hotel Operatorâs Occupation Tax (âHOOTâ) tax base by…
The U.S. statesâ tireless attempts at diminishing protections afforded under Public Law 86-272 (âP.L. 86-272â) have been headlining the state tax press for the last several years. For example, we saw, among other developments: (1) the MTC publish its revised Statement of Information (âMTC Statement of Informationâ) outlining proposed protected and unprotected activities under P.L. 86-272, including certain activities conducted over the Internet; (2) states (including California, New Jersey and New York) publish guidance seeking…
In Matter of Gatewood Corp, OTA Case No. 19105425 (July 3, 2024), the California Office of Tax Appeals (âOTAâ) concluded that Gatewood Corporationâs (âGatewoodâ) transfer of stock did not entitle it to a $10 million deduction because the transaction lacked economic substance and was for the purpose of tax avoidance, resulting in $831,398 additional tax. The California Franchise Tax Board (âFTBâ) conceded a $332,559 non-economic substance transaction (âNESTâ) penalty that it had originally imposed. In…
On October 17, 2022, a Maryland state judge in the Circuit Court of Anne Arundel County struck down the stateâs Digital Advertising Tax (âDigital Ad Taxâ) as violating the Internet Tax Freedom Act (âITFAâ) and the Commerce Clause and First Amendment of the U.S. Constitution. Comcast of California/Maryland/Pennsylvania/Virginia/West Virginia LLC, et al. v. Comptroller of the Treasury of Maryland, Case No. C-02-CV-21-000509 (Md. Cir. Ct. Anne Arundel Cnty.).  The judge issued her ruling from the…