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Transaction Taxes

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Artificial intelligence, or more commonly AI, seems to be what everyone is talking about nowadays.  Businesses are investing hundreds of billions into AI research and, in parallel, integrating AI products into their day-to-day operations in order to maximize business savings and obtain a competitive advantage over their competitors.  It is no secret the tax treatment of AI could have profound consequences for businesses.  However, most states have not made their position on the taxability of…

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…

The California legislature is proposing a 7.25% tax on “data extraction transactions in the state” through Senate Bill (“SB”) 1327. If enacted, the bill would target businesses that monetize data extracted from users (e.g., social media companies, large search engines, online retailers, etc.). “Data extraction transaction” means: “(A) A taxpayer sells user information or access to users to advertisers” and“(B) The taxpayer engages in a barter by providing services to a user in full or partial…