Last week at the NYU Intermediate Summer SALT Seminar, tax department leaders from across the country participated in a roundtable discussion, addressing topics such as department staffing, information sharing among states, and — everyone’s favorite — the fairness of retroactive legislation. My partner, Alysse McLoughlin, moderated the panel.

On the topic of retroactive legislation

Bloomberg Tax

Multinational corporations have long battled the IRS and other nations’ taxing authorities over their transfer pricing arrangements.

But transfer pricing examinations and disputes at the state level can be even more challenging due to a lack of consistency and transparency, particularly in states that require entities conducting a unitary business to file separate

Last week, South Carolina Governor McMaster signed into law Act No. 113 in a much needed reproach to the Department of Revenue’s aggressive attempts to undermine the state’s separate reporting regime for apportioning corporate income. While the law creates a new paradigm for how and in what manner the state or taxpayer may obtain alternative

The New York State Department of Taxation and Finance has formally proposed its 2015 corporate tax reform regulations under the State Administrative Procedure Act (SAPA). The regulations have been submitted for publication in the August 9, 2023 edition of the State Register

These regulations have a long history. There were several iterations of the

In Matter of Sunoco Inc. (R&M) Combined Affiliates, a Division of Tax Appeals Administrative Law Judge (ALJ) determined that Sunoco’s sale of oil pursuant to buy/sell arrangements was not a “sale” for purposes of computing Sunoco’s New York State Article 9-A sales factor.   The ALJ’s determination was based upon her finding that Sunoco was

The New York Budget Bill, SB.4009/A.B.3009, introduced on Sunday includes a provision allowing the NYS Department of Taxation and Finance (“Department”) to appeal determinations of the Tax Appeals Tribunal to the New York State Appellate Division under certain circumstances. Currently, the Tax Law allows only the taxpayer to appeal determinations of the Tax