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Interest and Penalties

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On June 16, 2025, Illinois Governor J.B. Pritzker signed House Bill 2755 (“H.B. 2755”) into law, which includes comprehensive amnesty programs covering taxes administered by both the Illinois Department of Revenue (the “Department”) and the Office of the Secretary of State of Illinois (the “Secretary of State”).  The legislation also introduces a new amnesty program for remote retailers under the state’s Remote Retailer Occupation Tax.  Under each program, in exchange for payment of any outstanding…

On May 31, 2025, the Illinois General Assembly passed HB2755 as part of the FY2026 budget bill, which contains a number of significant tax changes to the Illinois Income Tax Act and other taxes. Governor Pritzker appears set to sign the budget before July 1st. Major changes made by HB2755 include: (1) expanding the corporate income tax base with provisions specifically targeting multinational corporations, (2) expanding the Hotel Operator’s Occupation Tax (“HOOT”) tax base by…

Governor Hochul rang in the new year by vetoing a bill that expanded the New York State False Claims Act (“FCA”) to permit claims against non-filers. Specifically, on December 31, 2021, Governor Hochul vetoed Senate Bill S4730 (Assembly Bill A2543), explaining in Veto Message No. 83 that “the language in the bill is broader than impacting only non-filers, and would implicate more tax filing controversies to the False Claims Act than just non-filers. This would…

In Siemens USA Holdings Inc. v. Geisenberger, No. 20-2991 (3d Cir. 2021), the Third Circuit found that the District Court erred (1) in holding that Siemens’ preemption claim was unripe, and (2) in denying Siemens’ motion for a preliminary injunction.  Both the question of ripeness and the injunction request related to whether the escheat priority rules preempted certain audit procedures, as opposed to the validity of an assessment.  Specifically, Siemens brought the lawsuit claiming, among…