In an order released in July 2021, the Illinois Tax Tribunal denied a taxpayer’s motion for summary judgment in a “unitary business” case, finding that there were disputed issues of fact as to whether the taxpayer was engaged in a unitary business with a company that the taxpayer sold. See Christopher v. Illinois Dep’t of Rev., 19 TT 131 (Ill. Tax Trib. Nov. 24, 2020, released July 2021). The taxpayer, T. Christopher Holding Company (“Holding Company”), claimed that it was not unitary with Vogue International, LLC (“Operating Company”), and thus its gain from the sale of Operating Company could not be included in Holding Company’s Illinois business income under U.S. constitutional principles and Illinois law. However, the Tribunal found that the Illinois Department of Revenue (“Department”) had presented sufficient evidence to establish a disputed issue of material fact that rendered summary judgment on this issue inappropriate.
The Baker McKenzie SALT team presented the fourth session of its monthly webinar series covering coast-to-coast state and local tax developments on October 7, 2020. If you were unable to attend the session, links to the recording and materials are provided below: View the recorded webinar Download the materials
The New York State Department of Taxation and Finance (“Department”) recently published guidance stating that a nonresident’s income will be sourced to New York State unless the nonresident’s remote work location meets the “bona fide employer office” exception to the “convenience of the employer test.” Specifically, the Department addressed a question in its FAQs regarding how to source income for Personal Income Tax purposes where a nonresident’s primary office is in New York, but the…
The Baker McKenzie SALT team presented the third session of its monthly webinar series covering coast-to-coast state and local tax developments on September 2, 2020. This month’s webinar focuses on hearings and conferences in 2020, new and ongoing litigation, market facilitator updates and more. If you were unable to attend the session, links to the recording and materials are provided below: View the recorded webinar Download the materials