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Finishing SALT: Inside SALT’s Monthly Recap

Wrapping Up June Our June 2017 blog posts are available on insidesalt.com, or read each article by clicking on the titles below. To receive the latest on state and local tax news and commentary directly in your inbox as they are posted, click here to subscribe to our email list. June 5, 2017: Nexus is Crucial, Complex Connection for State Tax Professionals June 6, 2017: Substitute Alert – Delaware Technical Corrections Bill June 8, 2017: Inside SALT Event in McDermott Will & Emery’s New York Office New York, NY: The annual Inside SALT event took place on Thursday, June 8, 2017 in McDermott’s New York office. Tax lawyers Peter Faber, Todd Harrison, Stephen Kranz, Alysse McLoughlin, Art Rosen, Diann Smith and Mark Yopp presented a substantive half-day program highlighting many State and Local Tax updates, including recent changes specific to the New York area, Nexus developments in digital taxation, and news related to apportionment, transfer pricing and...

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Finishing SALT: InsideSALT’s Monthly Recap

Wrapping Up May – and Looking Forward to June Our May 2017 blog posts are available on our Inside SALT blog, or read each article by clicking on the titles below. To receive the latest on state and local tax news and commentary directly in your inbox as they are posted, fill out the form on the right to subscribe to our email list. May 16, 2017: Illinois Department of Revenue Affirms Cloud-Based Services Not Taxable In two recent General Information Letters (GILs), the Illinois Department of Revenue (Department) reaffirmed that computer software provided through a cloud-based delivery system is not subject to tax in Illinois. The Department announced that while it continues to review cloud-based arrangements and may determine they are taxable at some point, any decision to tax cloud-based services will be applied prospectively only. May 24, 2017: Illinois Bills to Watch Just days away from the May 31 close of its regular legislative session, the Illinois...

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District of Columbia’s Transfer Pricing Enforcement Program and Combined Reporting Regime: Taking Two Bites of the Same Apple

In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly implemented combined reporting tax regime is an effective means of increasing tax revenue from corporate taxpayers, but it will have little overlap with D.C.’s ongoing federal-style section 482 tax enforcement.  Dr. Cook is chief executive officer of Chainbridge Software LLC, whose company’s product and services have been utilized by the District to analyze corporations’ inter-company transactions and enforce arm’s length transfer pricing principles.  Combined reporting, (i.e., formulary apportionment, as it is known in international tax circles) and the arm’s length standard, are effectively polar opposites in the treatment of inter-company taxation.  It is inappropriate for the District (and other taxing jurisdictions) to simultaneously pursue both.  To do so seriously risks...

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Let the Training Begin: MTC Transfer Pricing Audits Draw Near

Deputy Executive Director Greg Matson (a nice guy at heart) announced this week that the Multistate Tax Commission (MTC) has hired its first transfer pricing training consultant and is scheduled to begin training state auditors.  The training, titled “Identifying Related Party Issues in Corporate Tax Audits” will be hosted by the North Carolina Department of Revenue from March 31 to April 1, 2015 in Raleigh, North Carolina.  While the much anticipated Arm’s Length Adjustment Service (ALAS, discussed in more depth in our February 6, 2015 blog post, available here) is still pending approval of the MTC Executive Committee and ratification at the annual meeting this summer, it has not stopped MTC officials from moving forward with training state auditors on transfer pricing.  This training (and any subsequent training offered before the annual meeting) will be conducted as part of the MTC’s “regular training” schedule (and is not directly tied to the ALAS program...

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Multistate Taxpayers Take Note! Recap of the First Day of the MTC Pricing Summit

On October 6, 2014, the Multistate Tax Commission (MTC) held the first day of a two-day meeting intended to educate state revenue authorities on corporate income tax issues surrounding intercompany transactions, and further refine a path forward for states interested in collaborating on audit and compliance strategies.  This first day focused entirely on presentations by specialists in transfer pricing and related intercompany transaction issues.  Two important themes and one blatant omission regarding future enforcement emerged from the first day:  (1) suggestions for increased disclosure and substantiation requirements; (2) safe harbor options and (3) a lack of discussion of how to prevent the risk of double taxation. Taxpayers should be particularly concerned with the stress placed by the specialists on increased disclosure and substantiation requirements.  Most of the specialists emphasized the importance of getting information into the hands of revenue...

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MTC State Transfer Pricing Program Looms on the Horizon

More formal, rigorous, and perhaps more frequent, state transfer pricing audits appear to be looming on the horizon, as the Multistate Tax Commission (MTC) is set to launch a design and development project tasked with presenting a preliminary draft program by year’s end, with a final program recommendation due by the MTC’s annual meeting in July 2015.  The intent would be to create a dedicated MTC program, including staff, that would assist, as well as train, member states (both combined and separate reporting states) in conducting state transfer pricing audits as an alternative to hiring contracted consultants. Read the full article.

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