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SALT Implications of the One Big, Beautiful Bill Act

By , and 17 Mins Read

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,…

Rhode Island Enters the Fray, Proposes Second in the Nation Digital Advertising Tax

By , , and 4 Mins Read

On February 6, 2025, Rhode Island lawmakers heard testimony about Rhode Island Governor Daniel McKee’s proposed Digital Advertising Gross Revenue Tax (“RI Ad Tax”).  If enacted, the RI Ad Tax, which is included in Governor McKee’s proposed 2026 budget released last month (HB 5076), would be the second of its kind in the U.S. after Maryland’s digital advertising tax.  Maryland’s digital advertising tax has been embroiled in litigation since its enactment and we expect the…

New Year, Same New York—Bill Proposes Significant Tax Increases for Corporations

By , and 5 Mins Read

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…

Maryland State Judge Strikes Down Digital Ad Tax

By , , , , , and 2 Mins Read

On October 17, 2022, a Maryland state judge in the Circuit Court of Anne Arundel County struck down the state’s Digital Advertising Tax (“Digital Ad Tax”) as violating the Internet Tax Freedom Act (“ITFA”) and the Commerce Clause and First Amendment of the U.S. Constitution.  Comcast of California/Maryland/Pennsylvania/Virginia/West Virginia LLC, et al. v. Comptroller of the Treasury of Maryland, Case No. C-02-CV-21-000509 (Md. Cir. Ct. Anne Arundel Cnty.).  The judge issued her ruling from the…

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