favorite blog posts (2009 to Present)

Helping Tax Departments Become The HERO

SALT and STRUCTURE: Keep it Simple Sxxxxx?

Define the Fight: Don't Lose an Audit Before It Starts

How Are You Protecting Your Company From State Taxes?

Are You Using Ambiguity to Your Advantage?

State Tax 'Strategery'

Welcome to SALT CRASHERS! (Home Depot & DIY Meets State Tax)

I Hate State Taxes and Why You Should To

How I Learned State Tax Planning is Essential

How State Taxes Impact Businesses of ALL Sizes

State Taxes and the Compound Effect: Ticking Time-Bomb or Nest-Egg?

Don't Let State Tax Blind Spots 'Wreck' Your Company

States Change Interpretation Without Any Change in Law?

Can You Rely on Informal Guidance?

Nonresident Withholding Nightmare

Year-End Tax Planning: Don't Forget the SALT

State Tax Practices: What People Think But Do Not Say

What's Your Favorite State Tax Conference (CPE)?

The Truth About State Tax Seminars

It Depends on the State

State Taxation: 'Food for Thought'

Legal Principles in State Taxation: Do You Know Them?

State Tax Requires 'Deep Work'

Why is SALT Thought Leadership So Hard?

Time for State Taxes to Be REWRITTEN

Should the Federal Government Pre-empt A State's Taxing Power?

Global Business and Technology Causes Overreaching Laws and Unintended Consequences

State Tax 'Think Tankers'

Why Do States Enact Bad Policy?

Retroactively Changing State Tax Legislation Creates Uncertainty

Does State Sovereignty Allow States to Overreach?

2009-2015 blog posts by major topics

• Nexus

  • Application of P.L. 86-272

  • Economic nexus

  • Use of independent contractors

  • Telecommuters

  • Attribution of activities

  • Foreign company (non-U.S.) company nexus despite no permanent establishment in U.S.

• Apportionment

  • Sourcing of Services

    • Market-Based Sourcing

  • Establishing the right to apportion

  • Inclusion of gross proceeds v. net gain in sales factor

  • Joyce v. Finnigan

  • Throwback / Throwout rules

  • Alternative apportionment (relief)

• Composition of Unitary business group

  • Composition of Combined / Consolidated group

  • Instant unity

  • Worldwide combination / Waters-Edge combination

  • Intercompany transactions (sales and eliminations)

  • Tax Havens

• Tax Base

  • Related party addbacks (royalties / interest)

  • Business v. Nonbusiness income

  • Conformity with Internal Revenue Code and federal elections

  • Foreign source income

• Tax Attributes

  • NOLS

    • Pre-apportionmed v. post-apportioned

    • I.R.C. Sec. 382 limitations

• Pass-Through Entities

  • Entity v. Aggregate theory

  • Unitary (tax base / factor flow-up) v. nonunitary (allocation)

  • Sale of partnership interest

  • Non-resident withholding compliance

  • Composite return filing options

  • Sourcing of guaranteed payments

  • Single-Member LLC obligations and liability

  • Multi-tiered entities (compliance and controversy)

• Procedure

  • Statute of limitation issues

  • Voluntary Disclosure Agreements

to view LS blog posts (800+) from 2009 to 2015 visit www.leveragestateandlocaltax.com.