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Multistate Tax  |  2024 Fourth Quarter Summary
State Tax Matters
State Tax Matters
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Administrative 

New York: New Law Expands Who May Appear before Division of Tax Appeals on Taxpayer’s Behalf
Orig Rel Date: October 4, 2024
Massachusetts: Draft Release Addresses Amnesty Program Offering Potential 100% Penalty Waiver that Begins November 1
Orig Rel Date: October 25, 2024
Pennsylvania: New Law Adds Layer of Potential Compromise in Tax Appeals Process at Board of Finance and Revenue
Orig Rel Date: November 1, 2024
Georgia Voters Appear to Back State Constitutional Amendment that Provides for Creation of New Tax Court
Orig Rel Date: November 8, 2024
Massachusetts: New Release Addresses Amnesty Program that Runs through December 30 and Offers Potential 100% Penalty Waiver
Orig Rel Date: November 8, 2024
Michigan: City of Detroit Will Accept Cryptocurrency as a Form of Payment Option for Certain Taxpayers
Orig Rel Date: November 15, 2024
Mississippi DOR Explains Voluntary Disclosure Lookback Periods When Returns are Not Filed
Orig Rel Date: December 20, 2024


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Income/Franchise 

California FTB Concedes Out-of-State Lender Does Not Owe Franchise Tax on Cardholders’ Credit Card Interest and Fees
Orig Rel Date: October 4, 2024
California: New Law Extends Indefinitely FTB Authority to Implement Electronic Notification Methods
Orig Rel Date: October 4, 2024
Michigan: Notice Clarifies that Income Tax Rate Reduction for TY 2023 Was Temporary
Orig Rel Date: October 4, 2024
New York: Advisory Opinion Explains Sourcing of Receipts from Sales and Installation of Lighting
Orig Rel Date: October 4, 2024
South Carolina: Information Letter Explains New Law on Alternative Apportionment and Forced Combination
Orig Rel Date: October 11, 2024
Federal: Bill Introduced in US Senate Seeks to Amend P.L. 86-272 by Defining Solicitation of Orders
Orig Rel Date: October 18, 2024
Indiana DOR Updates Guidance on Elective Entity-Level Tax for Pass-through Entities
Orig Rel Date: October 18, 2024
New Jersey Division of Taxation Describes Scope of Work as it Seeks Quotes for Transfer Pricing Specialists to Assist with CBT Audits
Orig Rel Date: October 18, 2024
New Jersey Division of Taxation Reminds of New Refundable Credit Related to Adoption of Convenience of the Employer Rule
Orig Rel Date: October 18, 2024
Pennsylvania DOR Addresses Implementation of Law Changes Involving Intercompany Intangible Expense Addback
Orig Rel Date: October 18, 2024
District of Columbia: Proposed Rule Requires Some Taxpayers to Attach Federal Return to Filed Return
Orig Rel Date: October 25, 2024
Iowa DOR Certifies that Corporate Income Tax Rate for Tax Years Beginning in 2025 Remains the Same
Orig Rel Date: October 25, 2024
Virginia Department of Taxation Issues Ruling on Exceptions to Intangible Expense Addback Statute
Orig Rel Date: October 25, 2024
Federal: Introduced US House Bill Seeks to Limit State Taxation of Compensation Earned by Nonresident Telecommuters and Other Multistate Workers
Orig Rel Date: November 8, 2024
Illinois PLR Says Temporary In-State Interruption of Shipment from Another State to Ultimate Out-of-State Location Does Not Impact Sourcing or Throwback
Orig Rel Date: November 8, 2024
Florida DOR Publishes Annual Guidance on Updated State Conformity to Internal Revenue Code
Orig Rel Date: November 15, 2024
Colorado DOR to Hold December 12 Workgroup Meeting to Discuss Rule on Partnerships Reporting Federal Tax Adjustments
Orig Rel Date: November 22, 2024
Indiana DOR Proposes New Rule on Market-Based Sourcing with Comments Due by December 13
Orig Rel Date: November 22, 2024
Massachusetts: Proposed Amended Nonresident Income Tax Rule Reflects How Pass-Through Entities Must Source Income
Orig Rel Date: November 22, 2024
Oregon: Taxpayer Petitions US Supreme Court to Review Whether its Activities Exceed P.L. 86-272 Protections
Orig Rel Date: November 22, 2024
Pennsylvania Supreme Court Reverses Ruling on Invalid NOL Cap by Rejecting Retroactive Refunds
Orig Rel Date: November 22, 2024
Virginia Appellate Court Affirms that DOR Unconstitutionally Tried to Tax Company’s Income from Non-Unitary LLC
Orig Rel Date: November 22, 2024
Michigan Department of Treasury Clarifies that Cryptocurrency Can’t Be Used to Pay Detroit Income Taxes
Orig Rel Date: December 6, 2024
New York: Receipts from Certain Buy/Sell Arrangements Cannot be Included in Receipts Factor
Orig Rel Date: December 6, 2024
Illinois DOR Addresses Sourcing Sales of TPP and Destination of Products to Third-Party Warehouses or Distribution Locations
Orig Rel Date: December 13, 2024
Louisiana: New Law Provides Flat 5.5% Corporate Tax Rate and Repeals Corporate Franchise Tax
Orig Rel Date: December 13, 2024
Maine: Proposed Rule Changes Seek to Clarify Sourcing Receipts from Services with Comments Due by January 17
Orig Rel Date: December 13, 2024
Michigan Department of Treasury Bulletin Addresses NOLs and Business Loss Computations Under Several Scenarios
Orig Rel Date: December 13, 2024
Minnesota Tax Court Holds Sourcing of Services Under Cascading Rules is Not Limited to Direct Customers
Orig Rel Date: December 13, 2024
New York City: Appellate Court Affirms that Commission Payments to Federal “DISC” are Nondeductible for UBT Purposes
Orig Rel Date: December 13, 2024
Ohio Supreme Court Affirms that Certain Services Must be Sourced In-State for CAT Purposes
Orig Rel Date: December 13, 2024
Arkansas Supreme Court Affirms that Taxpayer’s Spin-Off Interest Expenses are 100% Allocable to In-State Domicile
Orig Rel Date: December 20, 2024
Michigan: New Bulletin Reflects Updated Alternative Apportionment Procedures and Standards in Light of 2023 Caselaw
Orig Rel Date: December 20, 2024
Michigan: Parties’ Motions to Dismiss Denied in Case on Apportioning and Taxing Gain from Foreign Sale of Intellectual Property
Orig Rel Date: December 20, 2024
Michigan Department of Treasury Discusses Case Involving Insurance Affiliate and Combined Filing
Orig Rel Date: December 20, 2024
New York Court Dismisses Taxpayer’s Challenge of Certain Article 9-A Apportionment Rule Provisions
Orig Rel Date: December 20, 2024
Oregon: US Supreme Court Denies Taxpayer’s Petition to Review Whether its Activities Exceed P.L. 86-272 Protections
Orig Rel Date: December 20, 2024


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Gross Receipts 

Ohio: Changes to Transportation Service Provider Nexus Rule Reflect Increased CAT Exclusions
Orig Rel Date: October 11, 2024
Ohio: Motor Vehicle Sales to Ohio Customers at Out-of-State Locations Not Subject to CAT
Orig Rel Date: October 25, 2024
Washington DOR Asks for Comments on NFT Guidance by November 18
Orig Rel Date: October 25, 2024
Washington Supreme Court Agrees that Investment Funds are Ineligible for Investment Income Deduction
Orig Rel Date: November 1, 2024
California: San Francisco Voters Back Measure Revising Business Gross Receipts Taxes & Fees
Orig Rel Date: November 8, 2024
Washington DOR Posts Guidance on Business and Occupation Tax Apportionment and Sourcing
Orig Rel Date: November 8, 2024
Washington DOR Guidance Addresses Taxation of International Investment Management Services
Orig Rel Date: November 8, 2024


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Credits/Incentives 

California: New Law Modifies and Reestablishes Capital Investment Incentive Program through January 1, 2035
Orig Rel Date: October 4, 2024


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Sales/Use/Indirect 

California: New Law Requires Localities to Disclose Information on Sales Tax Sharing Agreements Made with Retailers
Orig Rel Date: October 4, 2024
Illinois: Retailers Deemed Liable Under False Claims Act and Owe Sales Tax on Installed Appliances
Orig Rel Date: October 4, 2024
Louisiana: Goods for Plant Production Potentially May Qualify for Manufacturing M&E Exclusion
Orig Rel Date: October 4, 2024
New York: Advisory Opinions Address Taxation of Computer Software and Related Services and Fees
Orig Rel Date: October 4, 2024
New York: Advisory Opinion Addresses Taxation of Information Services and Related Offerings
Orig Rel Date: October 4, 2024
New York: ITFA Prohibits Taxation of Email Services Whether or Not Packaged with Other Internet Access
Orig Rel Date: October 4, 2024
California: Special Notice Addresses New Law that Repeals Bad Debt Deduction for Lenders and Retailer Affiliates
Orig Rel Date: October 11, 2024
Illinois: Newsletter Summarizes New Law Addressing Retailers with In-State Physical Presence and Sourcing
Orig Rel Date: October 11, 2024
Missouri DOR Ruling Addresses if Online Ordering Company for Restaurant Food Delivery is a Marketplace Facilitator
Orig Rel Date: October 11, 2024
South Carolina Supreme Court Grants Taxpayer’s Request to Review Decision that Online Marketplace Owes Tax on Third-Party Sales
Orig Rel Date: October 11, 2024
South Dakota: US Supreme Court Denies Taxpayer’s Request to Review if Use Tax Imposition on Equipment’s One-Day Use In-State is Constitutional
Orig Rel Date: October 11, 2024
Texas: Letter Ruling Addresses Nexus Related to Imported Goods Stored in Bonded Area
Orig Rel Date: October 11, 2024
Ohio Board of Tax Appeals Says Services are Not Taxable when True Object is Data Authorization
Orig Rel Date: October 18, 2024
Pennsylvania DOR Addresses Taxability of Canned Computer Software, Digital Goods, and Related Services
Orig Rel Date: October 18, 2024
Texas: Processing Pre-Authorization Requests Using Proprietary Software Tool Deemed Not Taxable
Orig Rel Date: October 25, 2024
Washington DOR Asks for Comments on Draft MPU Exemption Guidance by November 4
Orig Rel Date: October 25, 2024
Illinois Appellate Court Affirms that Aircraft Owner Had Substantial Nexus Based on In-State Physical Presence
Orig Rel Date: November 1, 2024
New York: Business Consulting Advice Services are Taxable Information Services with Some Falling Under Statutory Exclusion
Orig Rel Date: November 1, 2024
Washington DOR Asks for Comments on Draft Multiple Points of Use Exemption Guidance by December 11
Orig Rel Date: November 8, 2024
Wisconsin DOR Summarizes Ruling that Contracts Created Taxable Sales/Leasebacks Rather than Nontaxable Refinancing
Orig Rel Date: November 8, 2024
Arizona Court of Appeals Addresses What Constitutes Processing Under Use Tax Manufacturing Exemption
Orig Rel Date: November 15, 2024
Georgia: Proposed Rule Reflects Taxation of Certain Retail Purchases and Sales of Specified Digital Products
Orig Rel Date: November 22, 2024
Illinois: Administrative Bulletin Summarizes New Law Addressing Retailers with In-State Physical Presence and Sourcing
Orig Rel Date: November 22, 2024
Massachusetts: Draft Proposed Changes to Rule on Taxation of Computer Software and Related Transactions
Orig Rel Date: November 22, 2024
Texas Comptroller of Public Accounts to Hold December 6 Hearing on Proposed Changes to Data Processing Services Rule
Orig Rel Date: November 22, 2024
Texas: Letter Rulings Address What Constitutes a Marketplace Provider Obligated to Collect and Remit Tax on Transactions
Orig Rel Date: November 22, 2024
California: December 9 Tax Workshop Solicits More Public Input on Technology Transfer Agreements
Orig Rel Date: December 6, 2024
California: December 16 Meeting Will Address New Requirements for Localities to Disclose Information on Sales Tax Sharing Agreements Made with Retailers
Orig Rel Date: December 6, 2024
Maryland: Company’s Equipment Deemed Predominantly Used in Exempt Production Activity Rather than Non-Exempt Delivery
Orig Rel Date: December 6, 2024
Texas District Court Stops Enforcement of Certain Provisions within Local Tax Situsing Rule
Orig Rel Date: December 6, 2024
Illinois: Proposed Rule Reflects New Law Requiring Direct Pay Permit Holders to Annually Verify Sourcing or Else Face Penalties
Orig Rel Date: December 13, 2024
Illinois: Remote Seller Challenges Constitutionality of Post-Wayfair “Leveling the Playing Field” Law
Orig Rel Date: December 13, 2024
Illinois Supreme Court Holds that Book Out Transactions are Not Necessarily Subject to Local Fuel Taxes
Orig Rel Date: December 13, 2024
Louisiana: New Law Defines and Provides for Taxation of Certain Digital Products With Some Exemptions
Orig Rel Date: December 13, 2024
Washington DOR Issues Guidance on Taxation and Sourcing of Non-Fungible Tokens (NFTs)
Orig Rel Date: December 13, 2024
Arizona: New Ruling Addresses Transaction Privilege and Use Tax Substantial Nexus and Sourcing
Orig Rel Date: December 20, 2024
Illinois: Destination-Based Sourcing Guidance for Remote Retailers, Marketplace Facilitators, and Some In-State Retailers
Orig Rel Date: December 20, 2024
Illinois: Bulletin Addresses Taxation of Certain Receipts from Leases and Rentals of TPP Beginning January 1
Orig Rel Date: December 20, 2024
Texas: Ruling Says Various Online Services Constitute Taxable Data Processing Rather Than Nontaxable Advertising
Orig Rel Date: December 20, 2024
Washington Supreme Court Affirms that Pharmacy Benefit Manager Qualifies for B&O Tax Exemption as Insurance Business
Orig Rel Date: December 20, 2024


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Unclaimed Property 

Delaware: Invitations for 2024 Unclaimed Property Voluntary Disclosure Agreement Coming Soon
Orig Rel Date: November 1, 2024


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Property 

Ohio: Commercial Property is Valued Based on Arm’s Length Sales Price Despite Proximity to COVID-19 Pandemic
Orig Rel Date: October 18, 2024
West Virginia: Non-Participating Royalty Interest in Oil and Gas Deemed Real Property Rather than Personal Property
Orig Rel Date: October 18, 2024


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Other/Miscellaneous/Transfer 

New York City: Real Property Transfer Tax Deemed Not Applicable Even Under Step Transaction Doctrine
Orig Rel Date: October 11, 2024
Minnesota: State High Court Affirms that Wholesale Drug Distributor May Exclude Customer-Earned Rebates from Gross Revenue Tax Base
Orig Rel Date: November 8, 2024


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Administrative

Income/Franchise

Gross Receipts

Credits/Incentives

Sales/Use/Indirect

Unclaimed Property

Property

Other/Miscellaneous

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