The Idaho Supreme Court recently affirmed a District Court’s judgment that the gain from the sale of a 78.54% membership interest in a limited liability company did not constitute “business income” under Idaho Code section 63-3027. In Noell Indus. Inc. v. Idaho State Tax Comm’n, Docket No. 46941 (Idaho 2020), the court determined that “this type of gain does not meet the definition of ‘business income’ under either the transactional test or functional test (including the unitary business test),” and was therefore not apportionable income.
Numerous states have provided tax relief in response to the COVID-19 outbreak, often in the form of tax filing and payment deadline extensions. At this time, 41 states and Washington, D.C. have provided a corporate income tax filing and/or payment deadline extension. Most recently, Florida extended its May 1, 2020 corporate income tax deadlines to August 3, 2020 for filing and June 1, 2020 for payment. Since the payment deadline is sooner than the filing deadline, the Florida Department of Revenue advised corporate taxpayers to submit payments based on their best estimate of the tax that would be due with the return. Some states have also extended income tax deadlines for partnerships and other business entities and many states have extended individual income tax deadlines.
Numerous states have provided tax relief in response to the COVID-19 outbreak, often in the form of tax filing and payment deadline extensions. At this time, 40 states and Washington, D.C. have provided a corporate income tax filing and/or payment deadline extension. Some of these states have conformed to the July 15 federal corporate income tax extension date, while others have extended to an earlier or later date. Some states have also extended income tax…
Since our previous blog post, several more states have provided tax relief by extending filing and payment deadlines in response to the COVID-19 (“coronavirus”) outbreak. However, numerous state tax departments are also canceling in-person customer service, which could make it more difficult for taxpayers to receive timely answers to their filing questions. We are also seeing the continued impact of COVID-19 on state and local tax litigation as more state courts and administrative tribunals adjourn hearing dates or move to conduct certain proceedings remotely.