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Illinois Brings Back Its Tax Amnesty Programs With A New Remote Retailer Feature

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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…

Qualified New York Manufacturer Wins at New York Division of Tax Appeals: Use of Third-Party Subcontractor Did Not Affect Eligibility for State Franchise Tax Reduced Rate

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The New York Division of Tax Appeals recently ruled in favor of a taxpayer, E. & J. Gallo Winery, holding that it met the statutory requirements of a “Qualified New York Manufacturer” (“QNYM”) and was therefore entitled to a reduced corporation franchise tax rate. As a result of New York’s corporate tax reform, QNYMs are entitled to a reduced tax rate, including a 0% tax rate on their business income base beginning in 2014, for…

Finding the Market Through the Looking Glass: California Issues Sales Factor Sourcing Guidance

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California’s long-anticipated market-based sourcing “guidance” is finally out. Legal Ruling No. 2022-01 provides the Franchise Tax Board’s take on how to find the market in certain business-to-business sales. Though the guidance emphasizes that a seller should look to where its direct customer receives the benefit of sales of services, it keeps with current market-based sourcing trends amongst states and directs taxpayers to source such receipts based on the location of the taxpayer’s customer’s customer. The…

New York State Issues Personal Income Tax Sourcing Guidance for Nonresident Employees Telecommuting Due to COVID-19 Pandemic

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The New York State Department of Taxation and Finance (“Department”) recently published guidance stating that a nonresident’s income will be sourced to New York State unless the nonresident’s remote work location meets the “bona fide employer office” exception to the “convenience of the employer test.”  Specifically, the Department addressed a question in its FAQs regarding how to source income for Personal Income Tax purposes where a nonresident’s primary office is in New York, but the…

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