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Multistate Tax  |  2025 Second Quarter Summary
State Tax Matters
State Tax Matters
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Administrative 

Kentucky: New Law Says Administrative Agencies are Not Entitled to Deference from Reviewing Courts
Orig Rel Date: April 4, 2025
Texas: New Law Addresses Whether Administrative Agencies are Entitled to Deference from Reviewing Courts
Orig Rel Date: May 2, 2025
New York City: Taxpayer Asks Federal Court to Hear UBT Dispute by Claiming Absence of ALJs at Tax Appeals Tribunal
Orig Rel Date: June 13, 2025
Oregon: New Law Establishes Uniform Statute of Limitations Periods for Refunds and Adjustments on Most Taxes
Orig Rel Date: June 27, 2025


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Amnesty/Voluntary Disclosure 

Indiana: New Law Requires Establishment of Amnesty Program that Provides for Potential Waiver of All Interest and Penalties
Orig Rel Date: May 9, 2025
Wisconsin DOR Reminds Businesses About Benefits of Participating in Voluntary Disclosure Program
Orig Rel Date: May 9, 2025
Illinois: New Law Requires Amnesty Program that Provides Potential 100% Interest and Penalty Waiver
Orig Rel Date: June 20, 2025


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Income/Franchise 

Colorado DOR Proposes New Rule on Partnerships Reporting Federal Tax Adjustments
Orig Rel Date: April 4, 2025
Kentucky: New Law Updates State Conformity to Internal Revenue Code
Orig Rel Date: April 4, 2025
Massachusetts DOR Proposes Amendments to Corporate Nexus Rule Addressing P.L. 86-272 and Internet Activity
Orig Rel Date: April 4, 2025
Michigan Department of Treasury Posts Guidance on New Refundable R&D Credit
Orig Rel Date: April 4, 2025
Oregon Tax Court Magistrate Says In-State Activities Create Substantial Nexus and Special Industry Apportionment Applies
Orig Rel Date: April 4, 2025
Texas: New R&D Credit Memos Indicate Depreciable Property Expenses Cannot Qualify as Supplies QREs and Federal Intra-Group Transaction Regs Do Not Apply to Texas R&D Credit
Orig Rel Date: April 4, 2025
Utah: New Law Lowers Corporate and Personal Income Tax Rates from 4.55% to 4.50%
Orig Rel Date: April 4, 2025
Idaho: New Law Clarifies Application of Recently Enacted Corporate Income Tax Rate Reduction
Orig Rel Date: April 11, 2025
Massachusetts Appeals Court Affirms that Individual’s Stock Sale in Company is Taxable Despite Subsequent Nonresidence
Orig Rel Date: April 11, 2025
Federal: Mobile Workforce State Income Tax Simplification Bill Has Been Introduced in US Senate
Orig Rel Date: April 18, 2025
Georgia: New Law Lowers Corporate Income Tax Rate and Contingently Phases in Additional Tax Rate Reductions
Orig Rel Date: April 18, 2025
Indiana: Updated Financial Institutions Tax Bulletin Addresses Combined Returns, PTET, and NOLs
Orig Rel Date: April 18, 2025
Kansas: New Law Provides for Contingent Corporate and Individual Income Tax Rate Reductions
Orig Rel Date: April 18, 2025
Texas: Timber Company’s Road Construction and Maintenance Costs Eligible for COGS
Orig Rel Date: April 18, 2025
Utah: Former Unitary Group Member Can’t Claim Portion of NOL Carryover Belonging to its Prior Unitary Group
Orig Rel Date: April 18, 2025
Arkansas: New Law Adopts Market-Based Sourcing, Bright-Line Nexus Standard, and Alternative Apportionment Provisions
Orig Rel Date: April 25, 2025
Michigan Tax Tribunal Says Taxpayer Successfully Showed Right to Apportion for City Income Tax Purposes
Orig Rel Date: April 25, 2025
Illinois DOR Denies Alternative Apportionment Requests as Taxpayers Failed to Show Unfair Representation of In-State Activity
Orig Rel Date: May 2, 2025
Kansas: New Law Adopts Single Sales Factor Apportionment and Market-Based Sourcing
Orig Rel Date: May 2, 2025
New Jersey: Retroactively Applying Rule Changes on CBT Royalty Expense “Addback” Exception Cures Violation
Orig Rel Date: May 2, 2025
New York: Retroactive Application of Article 9-A Rule on P.L. 86-272 and Internet Activity Violates Due Process
Orig Rel Date: May 2, 2025
Colorado DOR Issues Updated Guidance on Pass-Through Entity Tax that Addresses Tiered Structures
Orig Rel Date: May 9, 2025
Illinois DOR Publishes Guidance on Whether a Partnership Interest is a Qualifying Investment Security
Orig Rel Date: May 9, 2025
Massachusetts: Draft Release Summarizes New Law Revising Apportionment Provisions for Companies Without a Sales Factor
Orig Rel Date: May 9, 2025
Missouri: Proposed PTET Rule Changes Reflect New Opt-Out Election and Other Law Changes
Orig Rel Date: May 9, 2025
Tennessee: New Law Authorizes Excise Taxpayers to Make Discretionary Adjustments in Computing Tax Liability
Orig Rel Date: May 9, 2025
Virginia: Enacted Budget Bill Includes Provision that Extends Ability to Make PTET Election for One More Year
Orig Rel Date: May 9, 2025
Alabama: New Mobile Workforce Law Imposes Nonresident Withholding With 30-Day Threshold
Orig Rel Date: May 16, 2025
Massachusetts DOR Says Banks are Eligible for Research Tax Credits and May File Claims on Amended Returns or Abatement Applications
Orig Rel Date: May 16, 2025
New York Budget Extends Top Personal Income Tax Rates, Increases MCTMT Payroll Tax Rate for Some; Enacts Rules for Reporting Federal Partnership Audit Adjustments
Orig Rel Date: May 16, 2025
Virginia: Enacted Budget Bill Includes Provisions that Pause Rolling Conformity with Internal Revenue Code
Orig Rel Date: May 16, 2025
Alabama: New Law Retroactively Decouples from TCJA’s IRC §174 R&D Deduction Changes
Orig Rel Date: May 23, 2025
Alabama Circuit Court Says Exceptions to Intercompany Expense Addback Statute Do Not Apply and Subpart F Income Exclusion Overrides these Exceptions
Orig Rel Date: May 23, 2025
California FTB Posts Second Modified Text of Proposed Market-Based Sourcing Rule Changes with Comments Due by June 5
Orig Rel Date: May 23, 2025
Georgia: New Law Updates State Conformity to Internal Revenue Code
Orig Rel Date: May 23, 2025
Hawaii: New Law Revises PTET Provisions Pertaining to Qualified Members’ Credits for Taxes Paid
Orig Rel Date: May 23, 2025
Indiana: New Law Includes Sourcing Rules for Defined Investment Partnerships and Revises Some PTET Provisions
Orig Rel Date: May 23, 2025
Massachusetts: Out-of-State Company Deemed Corporate Excise Tax “Manufacturer” Required to Use Single Sales Factor Apportionment
Orig Rel Date: May 23, 2025
New York Tax Appeals Tribunal Denies Refund Request for Remote Work Performed Before and During COVID-19 Pandemic
Orig Rel Date: May 23, 2025
Texas: New Law Requires Registered Securities Market Operators to Exclude Certain Transaction Rebate Payments from Franchise Tax Base
Orig Rel Date: May 23, 2025
Washington: New Law Revises Several Provisions Under Capital Gains Tax and Seeks to Close “Loopholes”
Orig Rel Date: May 23, 2025
Illinois Appellate Court Affirms that Affiliate Was Not an 80/20 Company and Must be Included in Combined Return
Orig Rel Date: May 30, 2025
South Carolina: New Law Updates State Conformity to Internal Revenue Code
Orig Rel Date: May 30, 2025
Hawaii: New Law Updates State Conformity to Internal Revenue Code
Orig Rel Date: June 6, 2025
Illinois: Proposed Rule Changes Reflect Financial Institution Apportionment Revisions
Orig Rel Date: June 6, 2025
Virginia Supreme Court Denies Reviewing Holding that Department of Taxation Invalidly Tried to Tax Company’s Income from Non-Unitary LLC
Orig Rel Date: June 6, 2025
Wisconsin: Appellate Court Agrees that P.L. 86-272 Only Protects Sales of TPP, Not Services or Intangibles
Orig Rel Date: June 6, 2025
Missouri Court of Appeals Affirms REIT’s Rental Income is Subject to City Earnings Tax and Dividends Paid are Not Deductible
Orig Rel Date: June 13, 2025
Wisconsin: Appellate Court Agrees that Parent Failed to Show Intercompany Royalties Had Business Purpose and Economic Substance
Orig Rel Date: June 13, 2025
Illinois: Budget Bill Includes Finnigan Apportionment, Removal of Some Intercompany Expense Addback Exceptions, §163(j) Changes, and Partial GILTI Taxation
Orig Rel Date: June 20, 2025
Massachusetts: Release Summarizes 2024 Legislation that Revised Apportionment Provisions for Companies Without a Sales Factor
Orig Rel Date: June 20, 2025
Minnesota: New Law Makes Research Activities Credit Partially Refundable for Electing Taxpayers
Orig Rel Date: June 20, 2025
Nebraska: New Law Revises Procedures for Making PTET Election and Claiming Partner and Shareholder Credits
Orig Rel Date: June 20, 2025
New Jersey Division of Taxation Adopts New and Amended Rules Reflecting Significant CBT Law Changes from 2023
Orig Rel Date: June 20, 2025
Pennsylvania: City of Philadelphia Ordinance Lowers Business Income and Receipts Tax Rates and Ends $100K Exclusion
Orig Rel Date: June 20, 2025
Virginia: Legislative Summary Addresses Recent Law Changes that Pause Rolling Conformity with Internal Revenue Code
Orig Rel Date: June 20, 2025
Illinois DOR Denies Alternative Apportionment Request as Taxpayer Failed to Show Unfair Representation of In-State Activity
Orig Rel Date: June 27, 2025
Louisiana: New Law Modifies Filing Methodology for S Corps and Certain Mobile Workforce Provisions
Orig Rel Date: June 27, 2025
Maine: New Law Addresses Late Filing and Payment Logistics When Legislature Hasn’t Yet Addressed State Response to Federal Tax Law Changes
Orig Rel Date: June 27, 2025


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Gross Receipts 

Washington DOR Issues Guidance on B&O Tax Treatment of Collective Investment Vehicles and Investment Income
Orig Rel Date: April 25, 2025
California: San Francisco Tax Collector Launches VDA Program and Advance Written Determination Program
Orig Rel Date: May 2, 2025
California: San Francisco Tax Collector Posts Additional Information on Proposition M Implementation
Orig Rel Date: May 9, 2025
Washington: New Law Increases B&O Tax and Surcharge Rates and Clarifies Investment Income Deduction
Orig Rel Date: May 23, 2025
Washington: New Law Distinguishes Payment Card Processors and Provides for Special B&O Tax Rate and Deductions
Orig Rel Date: May 23, 2025
Washington: Ruling Says Out-of-State Company Has Nexus Based on In-State Activities of Contracted Service Providers
Orig Rel Date: May 23, 2025
Illinois General Information Letter Addresses Whether Online Platform Operates as Marketplace Facilitator
Orig Rel Date: June 6, 2025
Indiana Appellate Court Affirms Dismissal of Local Franchise Fee Suit Against Streaming Companies
Orig Rel Date: June 6, 2025
New York: Advisory Opinion Addresses if Retailer that Stores Inventory at Fulfillment Center’s In-State Warehouse is a Vendor
Orig Rel Date: June 6, 2025
New York: Advisory Opinion Concludes Charges for Accessing Mobile App and Dashboard are Taxable Receipts from Software Sale
Orig Rel Date: June 6, 2025
New York: Advisory Opinion Concludes that Financial Service Firm’s Charges for Accessing Trading Platform are Taxable Receipts from Software Sale
Orig Rel Date: June 6, 2025
New York: Advisory Opinion Addresses Taxability Related to Web-Based Job Search Platform
Orig Rel Date: June 6, 2025
Georgia Court of Appeals Affirms that Company Owes Atlanta Business Occupation Tax Based Only on Allocated Percentage of Gross Receipts
Orig Rel Date: June 20, 2025
Ohio Supreme Court Affirms that CAT Agency Exclusion Did Not Apply to Reimbursements from Management Fee Contracts
Orig Rel Date: June 20, 2025
Washington DOR to Launch Investment Income Voluntary Disclosure Program on July 1
Orig Rel Date: June 20, 2025
Washington DOR Posts Summary of 2025 B&O Tax, Sales and Use Tax, and Capital Gains Tax Law Changes
Orig Rel Date: June 20, 2025


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Credits/Incentives 

Kentucky: New Law Permits Localities to Create Economic Development Taxing Districts that Levy Property Tax and 3% Income Tax
Orig Rel Date: April 18, 2025
Texas: New Law Replaces Existing R&D Credit and Exemption with New R&D Franchise Tax Credit
Orig Rel Date: June 27, 2025


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Sales/Use/Indirect 

Washington DOR Posts Multiple Points of Use Exemption Guidance on Mixed Element Software Maintenance Agreements
Orig Rel Date: April 11, 2025
Illinois General Information Letter Says Tariffs are Not Deductible in Computing Retailers’ Occupation Tax Liability
Orig Rel Date: April 18, 2025
Illinois: New Rule Reflects How Direct Pay Permit Holders Must Now Annually Verify Sourcing or Else Face Penalties
Orig Rel Date: April 25, 2025
New York High Court Affirms that Offering Constitutes Taxable Information Services that Do Not Fall Under Statutory Exclusion
Orig Rel Date: April 25, 2025
Georgia: New Rule Reflects Taxation of Certain Retail Purchases and Sales of Specified Digital Products
Orig Rel Date: May 2, 2025
Maine Revenue Services Proposes Rule Reflecting Shift to Lease Stream Taxation of TPP Rentals
Orig Rel Date: May 2, 2025
New York: Provider’s Data Management Services Deemed Taxable Prewritten Software Sold as a Bundle Rather Than Nontaxable PaaS
Orig Rel Date: May 2, 2025
West Virginia: New Law Eliminates Certain Accelerated Tax Payment Requirements
Orig Rel Date: May 2, 2025
Georgia: Online Platform Held Responsible for Collecting Tax on Underlying Transportation Services for Pre-Wayfair Periods
Orig Rel Date: May 9, 2025
Mississippi Supreme Court Agrees that Charges Paid to Third-Party Carrier to Transport TPP In-State are Not Subject to Use Tax
Orig Rel Date: May 9, 2025
Texas: Ruling Says Bundled Subscription Services Constitute Taxable Data Processing Services
Orig Rel Date: May 9, 2025
Wisconsin DOR Reminds Businesses that Imposed Credit Card Fees Are Part of Taxable Sales Price
Orig Rel Date: May 9, 2025
Alabama: New Law Imposes Some Limits on Local Sales and Use Tax Exemption Enactments or Amendments
Orig Rel Date: May 16, 2025
Illinois: Posted FAQs Address Taxation of Certain Receipts from Leases and Rentals of TPP
Orig Rel Date: May 16, 2025
South Carolina: New Law Expands Eligibility for Durable Medical Equipment Exemption to Cure Constitutional Defect
Orig Rel Date: May 16, 2025
Maryland: New Law Imposes 3% Sales Tax on Certain Information Technology and Data Services
Orig Rel Date: May 23, 2025
New Jersey Division of Taxation Guidance Addresses Tax Treatment of Tariff Mark Ups
Orig Rel Date: May 23, 2025
Texas: Memo Explains Implications of Case that Exempted Equipment Used to Excavate TPP from Realty
Orig Rel Date: May 23, 2025
Washington: New Law Taxes Additional Services Including Advertising, Information Technology and Training
Orig Rel Date: May 23, 2025
Illinois DOR Proposes Rule Changes Reflecting Taxation of Receipts from Leases and Rentals of TPP
Orig Rel Date: May 30, 2025
New York: Telecom Deemed Not Liable for Sales Tax on Collected Federal Universal Service Fund Fees
Orig Rel Date: May 30, 2025
California: Special Notice Addresses Repeal of Bad Debt Deduction for Lenders and Retailer Affiliates
Orig Rel Date: June 13, 2025
South Carolina: Information Letter Addresses Revised Durable Medical Equipment Exemption that Cures Previous Constitutional Defect
Orig Rel Date: June 13, 2025
Illinois: Budget Bill Includes Remote Retailer Amnesty Program and Eliminates 200-Transaction Threshold from Economic Nexus Statute
Orig Rel Date: June 20, 2025
Louisiana: Newly Enacted Exemptions, Exclusions, Credits, and Rebates Must Apply to Both State and Local Taxes
Orig Rel Date: June 20, 2025
Maryland Comptroller Posts Guidance on New Law Imposing 3% Sales Tax on Certain Information Technology and Data Services
Orig Rel Date: June 20, 2025
Minnesota: New Law Mandates Accelerated Payments for Some Vendors and Includes 10% Late Payment Penalty
Orig Rel Date: June 20, 2025
Texas: Updated Memo Explains Implications of Case that Exempted Equipment Used to Excavate TPP from Realty
Orig Rel Date: June 20, 2025
Washington: Administrative Guidance Addresses Taxability of Live Presentations for Schools and Higher Education Institutions
Orig Rel Date: June 20, 2025
Illinois: Another General Information Letter Says Tariffs are Not Deductible in Computing Retailers’ Occupation Tax Liability
Orig Rel Date: June 27, 2025
Illinois: General Information Letter Concludes that Company Providing Online Ad Services is Not a Marketplace Facilitator
Orig Rel Date: June 27, 2025
Louisiana: New Law Includes Sales of Digital Products in Measure of Economic Nexus Threshold
Orig Rel Date: June 27, 2025
Maine: New Law Taxes Defined Digital Audiovisual and Digital Audio Services
Orig Rel Date: June 27, 2025
New Mexico Court of Appeals Reverses 2023 Ruling to Hold that Out-of-State Staffing Company is Exempt from Gross Receipts Taxation
Orig Rel Date: June 27, 2025
Texas: New Law Formally Excludes Internet Access Services from Taxation
Orig Rel Date: June 27, 2025
Texas: Services Offered to Satisfy Federal Prescription Drug Data Collection Reporting Obligations are Taxable Data Processing
Orig Rel Date: June 27, 2025
Utah: ALJ Concludes that Online Streaming Platform’s Subscription Fees are Fully Taxable as Bundled Transactions
Orig Rel Date: June 27, 2025


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Transfer 

Pennsylvania: Transfer of Interest in Real Estate Company Between Trusts Deemed Nontaxable
Orig Rel Date: May 23, 2025


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Unclaimed Property 

Texas Appellate Court Withdraws Earlier Ruling on Wind Farm Valuation Due to Subsequent Case Settlement
Orig Rel Date: April 4, 2025
Delaware: Invitations for 2025 Unclaimed Property VDA Program May be Coming Soon
Orig Rel Date: April 11, 2025
Michigan Supreme Court Holds in Companies’ Favor that Treasurer’s Examination Did Not Toll Statute of Limitations
Orig Rel Date: April 11, 2025
Washington: New Law Addresses Required Liquidation of Abandoned Virtual Currency
Orig Rel Date: April 11, 2025
Arizona: New Law Addresses Treatment and Reporting of Abandoned Digital Assets, Virtual Currency
Orig Rel Date: May 16, 2025
Maryland: New Law Addresses Required Liquidation of Abandoned Virtual Currency
Orig Rel Date: May 23, 2025
Colorado: New Law Addresses Abandoned Virtual Currency and Shortens Statute of Limitations Period
Orig Rel Date: June 13, 2025


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Property 

North Dakota: New Law Addresses Required Liquidation of Abandoned Virtual Currency
Orig Rel Date: April 4, 2025
Indiana: Newly Enacted Legislation Includes Several Property Tax Reforms and Relief Measures
Orig Rel Date: April 18, 2025
Indiana: New Law Revises Recently Enacted Property Tax Reforms and Relief Measures
Orig Rel Date: May 16, 2025
Ohio: Taxpayer Successfully Shows COVID-19 Pandemic Contributed to Reduced Hotel Valuation
Orig Rel Date: May 16, 2025
Alabama: New Law Increases Business Tangible Personal Property Exemption from $40K to $100K
Orig Rel Date: May 23, 2025
Texas: New Law Exempts All Intangible Personal Property from Ad Valorem Taxation
Orig Rel Date: May 30, 2025
Pennsylvania Supreme Court Says Taxpayer Qualified as Exempt Public Charity Despite Affiliate’s Executive Compensation
Orig Rel Date: June 6, 2025
Louisiana: New Law Increases Ad valorem Tax Exemption on Bank Stock
Orig Rel Date: June 20, 2025
Oklahoma: Transfer of Interest in Partnership that Holds Real Property Deemed a Transfer of Personal Property Rather than Realty
Orig Rel Date: June 20, 2025


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Other/Miscellaneous 

Maryland: New Law Establishes Appeals Process for Digital Advertising Gross Revenues Tax
Orig Rel Date: May 23, 2025


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Administrative

Amnesty/Voluntary Disclosure

Income/Franchise

Gross Receipts

Credits/Incentives

Sales/Use/Indirect

Transfer

Unclaimed Property

Property

Other/Miscellaneous

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