On July 4, 2025, President Donald Trump signed the One Big, Beautiful Bill Act (hereinafter, âOBBBAâ or âthe Actâ) into law. OBBBA enacts sweeping changes to the Internal Revenue Code (âCodeâ), many of which will impact taxpayers at the state level, including reforms to the federal state and local tax (âSALTâ) deduction, Global Intangible Low-Taxed Income (âGILTIâ), Foreign-Derived Intangible Income (âFDIIâ), section 174 research and development expensing, and section 163(j) business interest deduction limitations. Notably,…
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 taxpayersâ available GILTI exemptions, and at the same time almost double the top corporate franchise tax rate. Senate Bill 953 (âSB953â), 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…
A new lawsuit filed by Wayfair, LLC in Jefferson County Court (Colorado) seeks to address a question left open by the U.S. Supreme Courtâs landmark 2018 Wayfair decision that permits states to impose a sales or use tax collection obligation based on an economic nexus threshold: Does this decision apply to locally-administered sales or use taxes? While many localities have asserted that the same economic nexus standards should apply at the state and local levels,…
Ever since the U.S. Supreme Court overturned the physical presence nexus requirement for state sales and use taxes in South Dakota v. Wayfair, 138 S. Ct. 2080 (2018), taxpayers and practitioners have questioned the extent to which the Courtâs holding applies to locally administered sales and use taxes. This question is often rooted in the Courtâs statement in Wayfair that âStates may not impose undue burdens on interstate commerceâ and its reference to Pike v.…