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Public Law 86-272 – Federal Law Seeks to Giveth what the States Continue to Taketh Away with a Retroactive Twist

By , and 10 Mins Read

The U.S. states’ tireless attempts at diminishing protections afforded under Public Law 86-272 (“P.L. 86-272”) have been headlining the state tax press for the last several years. For example, we saw, among other developments: (1) the MTC publish its revised Statement of Information (“MTC Statement of Information”) outlining proposed protected and unprotected activities under P.L. 86-272, including certain activities conducted over the Internet; (2) states (including California, New Jersey and New York) publish guidance seeking…

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…

Nebraska Supreme Court Affirms Denial of “Deemed Dividend” Deduction For IRC §965 Income

By and 4 Mins Read

The one-time IRC §965 income inclusion for untaxed foreign earnings generated by a controlled foreign corporation (“CFC”) is not eligible for deduction from Nebraska taxable income as a “deemed dividend” according to a recent Nebraska Supreme Court decision, Precision Castparts Corp. v Nebraska Dept. of Revenue, 317 Neb. 481 (2024). Precision Castparts Corp. (“Taxpayer”), an aerospace component manufacturer, sought a declaratory order from the Nebraska Department of Revenue (“Department”) authorizing the company to amend its…

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