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Mike Shaikh

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California’s long-anticipated market-based sourcing “guidance” is finally out. Legal Ruling No. 2022-01 provides the Franchise Tax Board’s take on how to find the market in certain business-to-business sales. Though the guidance emphasizes that a seller should look to where its direct customer receives the benefit of sales of services, it keeps with current market-based sourcing trends amongst states and directs taxpayers to source such receipts based on the location of the taxpayer’s customer’s customer. The…

Beginning for tax year 2021, California will require businesses that file certain California tax returns to report their California unclaimed property filing history.  Specifically, most 2021 California business tax returns filed with the Franchise Tax Board (e.g., Forms 100, 565, and 568) have been updated to ask whether the entity has previously filed an unclaimed property Holder Remit Report with the State Controller’s Office, and if so, the date of the last report and the…

The Supreme Court has denied review of New Hampshire’s lawsuit against Massachusetts seeking to invalidate the latter’s controversial personal income tax sourcing regulation. The Supreme Court’s highly anticipated decision was likely influenced by the acting U.S. Solicitor General’s amicus brief arguing against the Supreme Court taking up the case. The Supreme Court has thus passed on reviewing the broader issue of whether and to what extent a state may impose its personal income tax on…

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).