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Income Tax

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The New York Division of Tax Appeals recently ruled in favor of a taxpayer, E. & J. Gallo Winery, holding that it met the statutory requirements of a “Qualified New York Manufacturer” (“QNYM”) and was therefore entitled to a reduced corporation franchise tax rate. As a result of New York’s corporate tax reform, QNYMs are entitled to a reduced tax rate, including a 0% tax rate on their business income base beginning in 2014, for…

California’s long-anticipated market-based sourcing “guidance” is finally out. Legal Ruling No. 2022-01 provides the Franchise Tax Board’s take on how to find the market in certain business-to-business sales. Though the guidance emphasizes that a seller should look to where its direct customer receives the benefit of sales of services, it keeps with current market-based sourcing trends amongst states and directs taxpayers to source such receipts based on the location of the taxpayer’s customer’s customer. The…

The New York State Department of Taxation and Finance (“Department”) recently published guidance stating that a nonresident’s income will be sourced to New York State unless the nonresident’s remote work location meets the “bona fide employer office” exception to the “convenience of the employer test.”  Specifically, the Department addressed a question in its FAQs regarding how to source income for Personal Income Tax purposes where a nonresident’s primary office is in New York, but the…

In the closely watched “Paula Trust” case, the California Court of Appeal, First Appellate District held that all of a trust’s California source income is subject to California income tax even though one of the trustees was a nonresident. Steuer v. Franchise Tax Board, No. A154691 (Cal. Ct. App. 1st Dist. June 29, 2020). The trust’s non-California source income would be apportionable. California imposes income tax on 100% of a trust’s income if all trustees…