Dmitrii Gabrielov, Author at SALT Savvy

Hopping On the Bandwagon: New Jersey Division of Taxation Unveils Voluntary Transfer Pricing Initiative

June 24, 2022 By Maria Eberle, Lindsay LaCava and Dmitrii Gabrielov 4 Mins Read

New Jersey is the latest state to unveil a voluntary initiative to examine transfer pricing for taxpayers with intercompany transactions. The initiative is similar to recent programs in North Carolina, Indiana, and Louisiana (see our prior coverage here and here, as well as our prior coverage of the Multistate Tax Commission’s ongoing transfer pricing collaboration and enforcement initiatives). The New Jersey Division of Taxation published guidance outlining the voluntary transfer pricing initiative last week (NJ…

Federal Judge Rules That Challenge to Maryland Digital Advertising Tax Cannot Proceed In Federal Court, But Challenge to Pass-Through Prohibition Can Proceed

March 8, 2022 By Maria Eberle, Ted Bots, Mark Yopp, Dmitrii Gabrielov and Ronald Beach 4 Mins Read

On March 4, 2022, a federal judge ruled that the federal Tax Injunction Act (“TIA”) bars a challenge to Maryland’s Digital Advertising Gross Revenues Tax (“Digital Ad Tax”) from proceeding in federal district court, but does not bar the plaintiffs from challenging Maryland’s prohibition on passing the tax to a customer “by means of a separate fee, surcharge, or line-item” (the “Pass-Through Prohibition”). Chamber of Commerce of the United States of America v. Franchot, No.…

Louisiana Latest State to Institute Voluntary Transfer Pricing Audit Program

November 1, 2021 By Maria Eberle, Lindsay LaCava, Mark Yopp, Nicole Ford, Drew Hemmings and Dmitrii Gabrielov 3 Mins Read

Beginning November 1, 2021, the Louisiana Department of Revenue (“Department”) will be offering taxpayers the opportunity to participate in a voluntary transfer pricing “managed audit” program (the “Program”). Pursuant to a recently released Department information bulletin, the purpose of the Program is to: Create an efficient and expedited resolution for corporate tax audits when transfer pricing issues exist; andProvide certainty and uniformity to taxpayers on the resolution of transfer pricing issues for open audit periods…

Connecticut’s Digital Advertising Tax Continues to Move Forward

June 2, 2021 By Maria Eberle, Lindsay LaCava, Mike Shaikh, Mark Yopp, Dmitrii Gabrielov and Joshua Lin 3 Mins Read

Connecticut legislative leaders recently announced support for a digital advertising tax (“Connecticut Digital Advertising Tax”) proposed by the Connecticut Joint Committee on Finance, Revenue and Bonding (the “Finance Committee”). Connecticut joins Maryland, Massachusetts, New York, and Texas, among others, as states with concrete digital advertising tax proposals on the table (and in Maryland’s case, an enacted law).