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New York Appellate Court Affirms Entity‑Level QETC Requirements for Combined Groups

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In Matter of Charter Communications, Inc. v New York State Tax Appeals Tribunal, CV-24-0971 the New York Supreme Court, Appellate Division, Third Department (New York’s intermediate appellate court, the “Court”) recently held that Charter Communications, Inc. and its combined affiliates were not eligible for the reduced qualified emerging technology company (“QETC”) corporate franchise tax rate. The Court agreed that each member of a combined group must independently meet the QETC definition for the group to…

New Year, New Taxes: Chicago Enacts Nation’s First Social Media Tax Among Other Changes

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The City of Chicago begins its 2026 fiscal year with a new budget containing several key tax changes (linked here), headlined by a new “Social Media Amusement Tax” (or “SMAT”). Here’s what you need to know to stay on top of your 2026 Chicago tax compliance obligations: The Chicago Social Media Amusement Tax A handful of U.S. jurisdictions have introduced the concept of a social media tax (e.g., California, Hawaii, Maryland, Minnesota, Washington, etc.) in…

Pennsylvania Supreme Court Strikes Down Pittsburgh’s “Jock Tax” on Nonresident Performers

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In a unanimous decision issued on September 25, 2025, the Pennsylvania Supreme Court invalidated the City of Pittsburgh’s controversial Nonresident Sports Facility Usage Fee (commonly referred to as the “Jock Tax”), a 3% levy imposed solely on nonresident athletes and entertainers who earn income at the City’s publicly funded sports stadiums. Pittsburgh residents were exempt from the fee. The Court held that the tax violated the Uniformity Clause of the Pennsylvania Constitution, which requires that…

SALT Implications of the One Big, Beautiful Bill Act

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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,…

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