On July 4, 2025, President Donald Trump signed the One Big, Beautiful Bill Act (hereinafter, “OBBBA” or “the Act”) into law. OBBBA enacts sweeping changes to the Internal Revenue Code (“Code”), many of which will impact taxpayers at the state level, including reforms to the federal state and local tax (“SALT”) deduction, Global Intangible Low-Taxed Income (“GILTI”), Foreign-Derived Intangible Income (“FDII”), section 174 research and development expensing, and section 163(j) business interest deduction limitations. Notably,…
Starting the new year off with legislation aimed directly at the pockets of corporate taxpayers, New York has issued a legislative proposal to nearly cut in half corporate taxpayers’ available GILTI exemptions, and at the same time almost double the top corporate franchise tax rate. Senate Bill 953 (“SB953”), pre-filed in the state senate on January 8, 2025, has the potential to significantly increase New York franchise tax exposure for corporations doing business in the…
Ever since the U.S. Supreme Court overturned the physical presence nexus requirement for state sales and use taxes in South Dakota v. Wayfair, 138 S. Ct. 2080 (2018), taxpayers and practitioners have questioned the extent to which the Court’s holding applies to locally administered sales and use taxes. This question is often rooted in the Court’s statement in Wayfair that “States may not impose undue burdens on interstate commerce” and its reference to Pike v.…
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…