Deloitte
Multistate Tax  |  2025 First Quarter Summary
State Tax Matters
State Tax Matters
The power of knowing.
 

Facebook Twitter Linkedin Linkedin

Administrative 

Pennsylvania DOR Addresses New Law Adding Layer of Potential Compromise in BFR Tax Appeals Process
Orig Rel Date: January 10, 2025
North Dakota: Updated Voluntary Disclosure Program Guidance Explains Lookback Period
Orig Rel Date: January 17, 2025
Multistate Tax Commission Executive Committee Accepts Nevada’s Request for Associate Membership
Orig Rel Date: January 24, 2025
Pennsylvania Department of State Reminds Businesses About New Annual Report Filing Requirement
Orig Rel Date: February 7, 2025


Top of Administrative list
Back to top

Income/Franchise 

California FTB to Hold January 30 Public Hearing on Proposed Market-Based Sourcing Rule Changes
Orig Rel Date: January 10, 2025
Hawaii Department of Taxation Adopts Temporary Rules Implementing Pass-Through Entity-Level Tax
Orig Rel Date: January 10, 2025
Louisiana DOR Summarizes New Law Providing Flat 5.5% Corporate Tax Rate and Repealing Corporate Franchise Tax
Orig Rel Date: January 10, 2025
Massachusetts: Amended Nonresident Income Tax Rule Reflects How Pass-Through Entities Must Source Income
Orig Rel Date: January 10, 2025
Massachusetts: New Law Revises Apportionment Provisions for Companies Without a Sales Factor
Orig Rel Date: January 10, 2025
New Jersey Tax Court Says Couple’s IRC §965 Deemed Repatriation Dividends are Not Subject to Gross Income Tax
Orig Rel Date: January 10, 2025
New York: Tribunal Affirms that Deferred Compensation Must Be Allocated Based on “BAP Method” from Years Earned
Orig Rel Date: January 10, 2025
Pennsylvania DOR Addresses Nexus and Voluntary Compliance Program for Online Retailers
Orig Rel Date: January 10, 2025
Tennessee Letter Ruling Addresses NOL and Credit Utilization Following IRC §368(a)(1)(F) Reorganization
Orig Rel Date: January 10, 2025
Tennessee: Updated Manual Reflects Ruling on Sourcing Sales of TPP Involving Distributors and Wholesalers
Orig Rel Date: January 10, 2025
Illinois: Court Says Subsidiary Was Not an 80/20 Company and Affiliate Operated as a Shell
Orig Rel Date: January 17, 2025
Michigan: New Law Creates Research and Development Corporate Income Tax Credit
Orig Rel Date: January 17, 2025
Pennsylvania: US Supreme Court Denies Taxpayer Request to Review Constitutionality of Philadelphia Wage Tax Scheme
Orig Rel Date: January 17, 2025
Tennessee Revenue Ruling Says Receipts from Drop Shipment Sales Are Sourced to Location of End User
Orig Rel Date: January 17, 2025
Tennessee Letter Ruling Addresses Combined Filing, Sale of Interests in Partnership Structure, and §338(h)(10) Election
Orig Rel Date: January 17, 2025
Virginia Department of Taxation Ruling Explains Intangible Expense Addback Statute and its Exceptions
Orig Rel Date: January 17, 2025
New York: US Supreme Court Rejects Taxpayer Requests to Review Decisions on Royalty Payments from Foreign Affiliates
Orig Rel Date: January 24, 2025
New York ALJ Denies Nonresident’s Refund Request for Remote Work Performed for Bank During COVID-19 Pandemic
Orig Rel Date: January 24, 2025
Ohio: Electricity Company Deemed Exempt from Local Taxing Authority’s Net Profits Tax
Orig Rel Date: January 24, 2025
Virginia: Administrative Ruling Says Manufacturer May Elect Modified Apportionment Method on Amended Return
Orig Rel Date: January 24, 2025
Virginia: Administrative Ruling Says Loan Interest to Purchase Stock is Not Subject to Intercompany Addback Statute
Orig Rel Date: January 24, 2025
California: Partnership Income from Stock Sale Deemed Apportionable Rather Than Sourced Entirely In-State
Orig Rel Date: January 31, 2025
Hawaii Department of Taxation Adopts Temporary Rules Implementing Pass-Through Entity-Level Tax
Orig Rel Date: January 31, 2025
Idaho: New Law Generally Updates State Conformity to Internal Revenue Code
Orig Rel Date: January 31, 2025
Indiana: Tax Base and Apportionment Calculations for Foreign Corporation in Toll Manufacturing Arrangement
Orig Rel Date: January 31, 2025
District of Columbia: Amended Rule Requires Some Taxpayers to Attach Federal Return to Filed Return
Orig Rel Date: February 7, 2025
Illinois: Adopted Rule Changes Reflect Legislation Limiting NOL Deduction to $500K
Orig Rel Date: February 7, 2025
Maine: Revised Rule Proposal Seeks to Clarify Sourcing Receipts from Services with Comments Due by March 3
Orig Rel Date: February 7, 2025
Federal: Bill Introduced in US House Seeks to Amend P.L. 86-272 by Defining Solicitation of Orders
Orig Rel Date: February 14, 2025
Michigan Department of Treasury Explains Implementation of Law Changes Involving Passthrough Entity Tax
Orig Rel Date: February 14, 2025
New York: Tribunal Affirms that Single-Purpose Investment Entity is Excludable from Affiliates’ Combined Return
Orig Rel Date: February 14, 2025
Illinois DOR Reminds of Possible Penalties Related to Abusive Tax Avoidance Transactions
Orig Rel Date: February 21, 2025
Michigan Tax Tribunal Holds that Wholesale Electricity Sales Must Be Sourced Entirely In-State Rather than Ultimate Destination
Orig Rel Date: February 21, 2025
New Jersey: Proposed New and Amended Rules Reflect Significant CBT Law Changes from 2023
Orig Rel Date: February 21, 2025
South Dakota: New Law Updates State Conformity to Internal Revenue Code for Bank Tax Purposes
Orig Rel Date: February 21, 2025
Georgia: Amended Rule Reflects State Law Permitting Some Affiliates to File Consolidated Income Tax Return
Orig Rel Date: February 28, 2025
Ohio BTA Denies Relief to Taxpayer Challenging Validity of Financial Institution Tax Rate Structure
Orig Rel Date: February 28, 2025
West Virginia: New Law Generally Updates State Conformity to Internal Revenue Code
Orig Rel Date: February 28, 2025
Arizona: New Law Updates State Conformity to Internal Revenue Code
Orig Rel Date: March 7, 2025
California FTB Summarizes 2024 Legislation that Suspended NOLs and Limits Some Credits
Orig Rel Date: March 7, 2025
California Office of Tax Appeals Issues Decision on Nonqualified Entity’s Jurisdiction to Appeal
Orig Rel Date: March 7, 2025
Indiana DOR Adopts New Rule Reflecting 2019 Implementation of Market-Based Sourcing
Orig Rel Date: March 7, 2025
Indiana: Out-of-State Equity Firm Successfully Showed its Apportionment Factor is Zero Rather than 100%
Orig Rel Date: March 7, 2025
New Hampshire: Water’s Edge Combined Group Allowed to Offset Capital Gains with Member’s Capital Loss Carryback
Orig Rel Date: March 7, 2025
New York Tax Appeals Tribunal Reverses ALJ Holding that Permitted Investment Bank to Source Income from Securities Transactions Using Alternate Method
Orig Rel Date: March 7, 2025
Idaho: New Law Implements Additional Corporate and Personal Income Tax Rate Reductions
Orig Rel Date: March 14, 2025, 2025
New Mexico Ruling Addresses Sourcing Sales of TPP Delivered to Third-Party Distribution Warehouses
Orig Rel Date: March 14, 2025, 2025
Ohio: New Law Generally Updates State Conformity to Internal Revenue Code
Orig Rel Date: March 14, 2025, 2025
Illinois Appellate Court Affirms that Affiliate Was Not an 80/20 Company and Must be Included in Combined Return
Orig Rel Date: March 21, 2025
South Carolina DOR Posts Draft Guidance on Sourcing Receipts from Services
Orig Rel Date: March 21, 2025
Texas: COGS Deduction and Reduced Rate Do Not Apply Given Receipts Were Derived from the Sale of Services Rather than Goods
Orig Rel Date: March 21, 2025
Michigan: Newsletter Discusses R&D Credit, Case on Sourcing Wholesale Electricity Sales, Alternative Apportionment, and PTET
Orig Rel Date: March 28, 2025
Oregon Tax Court Magistrate Says In-State Activities Create Substantial Nexus and Special Industry Apportionment Applies
Orig Rel Date: March 28, 2025
Oregon Tax Court Magistrate Says Captive Insurer Payments are Deductible Despite IRS Settlement Agreement
Orig Rel Date: March 28, 2025
Utah: New Law Revises Financial Institution Sourcing Provisions and Requires Annual Study of Federal Tax Law Changes
Orig Rel Date: March 28, 2025


Top of Income/Franchise list
Back to top

Gross Receipts 

Washington DOR Addresses Taxation of Tariff and Credit Card Processing Fee Surcharges
Orig Rel Date: January 10, 2025
Washington DOR Addresses 2024 Decision that Denied Investment Income Deduction Claimed by Investment Funds
Orig Rel Date: January 24, 2025
Washington: Some Content Delivery Network Services Deemed Taxable and Sourced Based on Location of End-Users
Orig Rel Date: March 14, 2025, 2025
California: San Francisco Tax Collector Proposes Market Sourcing Rules for Revised Business Tax
Orig Rel Date: March 21, 2025
Virginia: New Law Requires Study to Potentially Broaden BPOL Deduction for Receipts Attributable to Out-of-State Business
Orig Rel Date: March 28, 2025
Washington: Updated Guidance on 2024 Decision that Denied Investment Income Deduction Addresses Endowments
Orig Rel Date: March 28, 2025


Top of Gross Receipts list
Back to top

Credits/Incentives 

South Carolina Appellate Court Says $5 Million Credit Cap Applies Annually and is Not a Lifetime Limit
Orig Rel Date: March 28, 2025


Top of Credits/Incentives list
Back to top

Sales/Use/Indirect 

Georgia Letter Ruling Addresses Taxable Sales of Prewritten Computer Software and MPU Exemption
Orig Rel Date: January 10, 2025
Illinois: US District Court Grants Partial Preliminary Injunction of New Law Prohibiting Certain Interchange Fees
Orig Rel Date: January 10, 2025
Illinois Private Letter Rulings Address Taxability of Online and Mobile Application Access to Software
Orig Rel Date: January 10, 2025
Louisiana DOR Summarizes New Law Defining and Taxing Certain Digital Products with Some Exemptions
Orig Rel Date: January 10, 2025
Maine Revenue Services Reminds that New Law Shifted to Lease Stream Taxation of TPP Rentals as of January 1
Orig Rel Date: January 10, 2025
Missouri: Court Dismisses Local Franchise Fee Suit Against Streaming Companies Based on 2024 Legislation
Orig Rel Date: January 10, 2025
North Carolina: Administrative Law Judge Addresses Taxability of Various Intercompany Transfers
Orig Rel Date: January 10, 2025
Texas: Company’s Hosting of Cryptocurrency Mining Hardware Machines at Facility Deemed Not Taxable
Orig Rel Date: January 10, 2025
Texas: Service Provider Fails to Show that its Purchased Cloud Services Qualify for Resale Exemption
Orig Rel Date: January 10, 2025
Colorado: February 20 Meeting Will Address Draft Proposed Rule on Taxability and Sourcing of Mainframe Computer Access
Orig Rel Date: January 24, 2025
Illinois: New Guidance Addresses In-State Physical Presence for Sellers and Sourcing Underlying Sales
Orig Rel Date: January 24, 2025
Ohio: New Law Addresses Taxation of Delivery Network Companies Operating as Marketplace Facilitators
Orig Rel Date: January 24, 2025
Indiana: Video Game Publisher’s Optional Subscriptions, In-Game Items, and Virtual Currency are Not Taxable
Orig Rel Date: January 31, 2025
Tennessee: True Object of Website Design and Consulting is Nontaxable Service Rather than Taxable Software Sale
Orig Rel Date: January 31, 2025
North Carolina: Online Subscription Fees to Access and Use Digital Products Deemed Taxable Bundled Transaction
Orig Rel Date: February 7, 2025
Pennsylvania: Non-Voice Private Line Services that Transport Data are Deemed Taxable Phone Messages
Orig Rel Date: February 7, 2025
Rhode Island: DNA Testing and Subsequent Access to Online Reports Constitutes Taxable Vendor-Hosted Software
Orig Rel Date: February 7, 2025
Wisconsin DOR Updates Guidance on Sales and Purchases of Digital Goods and Computer Software
Orig Rel Date: February 7, 2025
Illinois: Proposed Rule Changes Reflect New Destination-Based Sourcing for Some Retailers
Orig Rel Date: February 14, 2025
Illinois: Letter Rulings Address Taxation of Certain Receipts from Leases and Rentals of TPP as of January 1
Orig Rel Date: February 14, 2025
Illinois: Letter Rulings Address Taxation of Video Games, In-Game Items and Virtual Currency
Orig Rel Date: February 14, 2025
Illinois: Letter Ruling Addresses Tax Implications of Credit Card Fees for Retailers
Orig Rel Date: February 14, 2025
New Mexico: Ruling Addresses Gross Receipts Taxability and Sourcing of Markeplace Provider’s Various Fees
Orig Rel Date: February 14, 2025
California Department of Tax and Fee Administration Explains When Retailer is Engaged in Business within Locality
Orig Rel Date: February 21, 2025
Illinois Letter Ruling Addresses Definition of Marketplace Facilitator in Context of Internet Auction Listing Service
Orig Rel Date: February 21, 2025
Colorado: Letter Ruling Addresses Sourcing Sale of Goods Involving Third-Party Shipping Company
Orig Rel Date: February 28, 2025
Kentucky: Combo Deli and Grocer Deemed Perishable Prepared Food Manufacturer Eligible for Exemption
Orig Rel Date: March 7, 2025
California: Emergency Rule Addresses New Requirements for Localities to Disclose Information on Sales Tax Sharing Agreements Made with Retailers
Orig Rel Date: March 14, 2025, 2025
Washington BTA Says Internet Radio Service Provider Qualifies for Radio Broadcaster Sales Tax Exemption
Orig Rel Date: March 14, 2025, 2025
Wyoming: New Law Extends Sunset Date of Manufacturing Exemptions to December 31, 2042
Orig Rel Date: March 14, 2025, 2025
Pennsylvania DOR Says it Will No Longer Accept Vendor Attestation Letters on Certain Taxpayer Refund Requests
Orig Rel Date: March 21, 2025
Colorado: New Law Sets Confidentiality Standards for Localities Using Third-Party Auditors
Orig Rel Date: March 28, 2025
Illinois Appellate Court Explains Chicago Lease Taxation on Financing Company’s Vehicle Lease Assignments
Orig Rel Date: March 28, 2025
Maine Revenue Services Proposes Rule Reflecting Shift to Lease Stream Taxation of TPP Rentals
Orig Rel Date: March 28, 2025
South Carolina DOR Explains Tax Implications of Retailers Withdrawing Items from Inventory for Use
Orig Rel Date: March 28, 2025
Texas Comptroller of Public Accounts Adopts Changes to Data Processing Services Rule
Orig Rel Date: March 28, 2025
Utah: New Law Removes 200-Transaction Threshold from Wayfair Economic Nexus Statute and Clarifies Amnesty Period for Errors
Orig Rel Date: March 28, 2025


Top of Sales/Use/Indirect list
Back to top

Unclaimed Property 

Delaware: Reminder: Voluntary Disclosure Agreement Invitation Response Deadline is Approaching
Orig Rel Date: February 7, 2025
Rhode Island: New Rule Addresses Payment or Delivery of Virtual Currency to Administrator
Orig Rel Date: March 7, 2025
South Dakota: New Law Addresses Required Liquidation of Abandoned Virtual Currency
Orig Rel Date: March 21, 2025


Top of Unclaimed Property list
Back to top

Property 

Texas Appellate Court Says Wind Farm Valuation Erroneously Included Nontaxable Intangible Personal Property
Orig Rel Date: January 10, 2025
Arizona High Court Says Utility Company’s Valuation for Plant in Service Can be Negative
Orig Rel Date: February 7, 2025
Ohio Board of Tax Appeals Holds that COVID-19 Pandemic Impacted TY 2020 Hotel Valuation
Orig Rel Date: March 7, 2025
Wyoming: New Law Increases Business Property Tax Exemption and Enacts Fair Market Value Limitations on Certain TPP
Orig Rel Date: March 7, 2025


Top of Property list
Back to top

Other/Miscellaneous 

Washington: City of Seattle Voters Back New 5% Employer Tax on Excess Compensation
Orig Rel Date: February 21, 2025


Top of Other/Miscellaneous list
Back to top

 
Administrative

Income/Franchise

Gross Receipts

Credits/Incentives

Sales/Use/Indirect

Unclaimed Property

Property

Other/Miscellaneous

Multistate Tax Alerts archive



Helpful resources

State tax Matters archive

Multistate Tax on D.com

Read Accounting for Income Taxes

Join Dbriefs

Visit tax@hand



Have a question?

If you have needs specifically related to this newsletter's content, send us an email to have a Deloitte Tax professional contact you.
 

Deloitte.com  |  Legal  |  Privacy

30 Rockefeller Plaza
New York, NY 10112-0015
United States

About Deloitte
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities (collectively, the “Deloitte organization”). DTTL (also referred to as “Deloitte Global”) and each of its member firms and related entities are legally separate and independent entities, which cannot obligate or bind each other in respect of third parties. DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of each other. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.

Deloitte provides industry-leading audit and assurance, tax and legal, consulting, financial advisory, and risk advisory services to nearly 90% of the Fortune Global 500® and thousands of private companies. Our professionals deliver measurable and lasting results that help reinforce public trust in capital markets, enable clients to transform and thrive, and lead the way toward a stronger economy, a more equitable society and a sustainable world. Building on its 175-plus year history, Deloitte spans more than 150 countries and territories. Learn how Deloitte’s approximately 415,000 peopleworldwide make an impact that matters at www.deloitte.com.

Copyright © 2024 Deloitte Development LLC. All rights reserved.
36 USC 220506



Facebook Linkedin Google Plus Email