Kathleen M. Quinn

Subscribe to Kathleen M. Quinn's Posts
Kathleen Quinn focuses her practice on state and local tax matters. She represents business and individual taxpayers at all stages of state and local tax controversies, including the audit, administrative, and judicial levels. Kathleen also advises clients on state and local tax planning opportunities and the state and local tax consequences of corporate restructurings and other business transactions. Read Kathleen Quinn's full bio. 

Pennsylvania Cuts Corporate Tax Rate, Makes Other Changes to Corporate Tax Law


By , and on Jul 14, 2022
Posted In Federal Tax, Income Tax, Local Tax, Nationwide Importance, Nexus, Pennsylvania

Pennsylvania Governor Tom Wolf has signed into law omnibus tax legislation to implement the Commonwealth’s fiscal year 2022 – 2023 budget. Among other things, the enacted legislation: (1) cuts the corporate net income tax (CNIT) rate from 9.99% to 4.99% on a phased-in basis; (2) adopts market sourcing rules for intangible-related receipts; and (3) codifies the Pennsylvania...

Continue Reading



“Voluntary” in Name Only? New Jersey Introduces Transfer Pricing Initiative


By , , and on Jun 16, 2022
Posted In Audits, Income Tax, Interest and Penalties, New Jersey, Transfer Pricing

The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted toward companies that have intercompany transactions that would be subject to transfer pricing adjustment. The initiative is broadly available to taxpayers with related...

Continue Reading



New York State Department Intends to Finalize Corporate Tax Regulations This Fall


By , and on May 2, 2022
Posted In Allocation/Appointment, Federal Tax, Local Tax, Nationwide Importance, New York

Almost seven years after it started releasing draft regulations concerning sweeping corporate tax reforms that went into effect back in 2015, the New York State Department of Taxation and Finance (Department) has issued guidance, stating that “the Department intends to begin the State Administrative Procedure Act (SAPA) process to formally propose and adopt” its draft...

Continue Reading



Nebraska District Court Holds That GIL 24-19-1 is Not Afforded Deference


By , and on Jun 24, 2021
Posted In Federal Tax, Income Tax, Local Tax, Nationwide Importance, Tax Base

Last week, the Lancaster County District Court granted the state’s motion to dismiss in COST v. Nebraska Department of Revenue. COST brought this declaratory judgment action to invalidate GIL 24-19-1, in which the department determined that earnings deemed repatriated under IRC § 965 are not eligible for the state’s dividends-received deduction and are thus subject...

Continue Reading



US Treasury Issues Guidance on the ARPA Claw-Back Provision


By , and on May 12, 2021
Posted In Constitutional Issues, Franchise Tax, Income Tax, Insurance Tax, Local Tax, Nationwide Importance, Property Tax, Sales Tax, Tax Base, Transaction Taxes

Earlier this week, the US Department of the Treasury (Treasury) issued formal guidance regarding the administration of the American Rescue Plan Act of 2021 (ARPA) claw-back provision. The guidance (Interim Final Rule) provides that the claw-back provision is triggered when there is a reduction in net tax revenue caused by changes in law, regulation or...

Continue Reading



Kansas Decouples from GILTI and 163j


By and on May 4, 2021
Posted In Federal Tax, Income Tax, Kansas, Tax Base

Yesterday afternoon the Kansas legislature overrode Governor Laura Kelly’s veto of Senate Bill (SB) 50, effectively enacting the provisions of the bill into law. Among those are provisions decoupling from certain Tax Cuts and Jobs Act (TCJA) provisions that taxpayers have been advocating for since 2018. Under the new law, for tax years beginning after...

Continue Reading



The US Department of the Treasury Says State IRC Conformity Bills Do Not Trigger Federal Relief Claw-Back Provision


By , and on Apr 9, 2021
Posted In Constitutional Issues, Franchise Tax, Gross Receipts Tax, Income Tax, Insurance Tax, Local Tax, Nationwide Importance, Property Tax, Sales Tax, Tax Base, Transaction Taxes

As we’ve blogged about in the past, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes an ambiguous claw-back provision. If broadly interpreted, it could result in states losing relief funding provided under the APRA if there is any state legislative or administrative change that results in the reduction of state revenue. This...

Continue Reading



McDermott Provides Treasury Department with Concrete Suggestions for Guidance on the American Rescue Plan Act’s Claw-Back Provision


By , and on Mar 25, 2021
Posted In Constitutional Issues, Franchise Tax, Gross Receipts Tax, Income Tax, Insurance Tax, Local Tax, Nationwide Importance, Property Tax, Sales Tax, Tax Base, Transaction Taxes

The recently enacted American Rescue Plan Act of 2021 (ARPA) includes an ambiguous claw-back provision that has brought the world of state and local tax policymaking to a grinding halt. Because ARPA’s adoption occurred during the final weeks of many states’ legislative sessions, rapid issuance of guidance from the US Department of the Treasury is...

Continue Reading



Connecticut Bill Aims to Address the Impact of Telecommuting during the Pandemic


By and on Mar 8, 2021
Posted In Connecticut, Income Tax, Local Tax, Nationwide Importance

As we continue to face growing concerns because of the nationwide impact of COVID-19, taxpayers should be mindful of the potential impacts that the continued rise in telecommuting may have on their state personal income tax liabilities. A bill was recently introduced in Connecticut that partially addresses this situation. Connecticut House Bill No. 6513 (HB...

Continue Reading



New York Issues Much-Anticipated Guidance on Taxation of Telecommuting Employees


By , and on Oct 23, 2020
Posted In Income Tax, Local Tax, Massachusetts, Nationwide Importance, New Hampshire, New Jersey, New York

Since the outset of the COVID-19 pandemic and work-from-home mandates, New York employers and their nonresident employees have been waiting for the Department of Taxation and Finance to address the million-dollar question: Do wages earned by a nonresident who typically works in a New York office but is now telecommuting from another state due to...

Continue Reading



STAY CONNECTED

TOPICS

ARCHIVES