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State Taxation

  • America, Love It or Leave It!: Tax Consequences of Citizenship Renunciation

    By:
    Alicea Castellanos, CPA
    |
    Feb 1, 2021
    During the tumultuous protests against the Vietnam War in the late ’60 s and ’70s, many pro-war activists decried the slogan “America, love it or leave It!” The meaning behind the slogan is that there is no middle road when proclaiming allegiance and loyalty to the United States—that is, you are either supportive of your country and the decisions made by its government, or if not, you have the choice to live elsewhere. It is a highly emotional proclamation reminiscent of a time in this country when people were deeply divided on life-and-death issues. 

  • SALT Business: A Glimpse in the Eye of the Pandemic

    By:
    Timothy P. Noonan, JD and Doran J. Gittelman
    |
    Jan 1, 2021
    There has been no shortage of excitement in the State and Local Tax (SALT) world this year. Between state-issued COVID-19 guidance, federal stimulus efforts, and the ever-changing landscape of income sourcing and nexus rules, individuals and multistate businesses are struggling to remain tax compliant. In this article, we will focus on some of the hot topics in state and local tax this year, and touch upon some of the big shifts occurring during the pandemic. 

  • New York Issues Guidance on How to Report the Decoupling from the CARES Act on the Personal Income on Tax Forms IT-201, IT-203, IT-204 and IT-205

    By:
    Mark H. Levin, CPA, MS (taxation)
    |
    Jan 1, 2021

    Ever since New York decoupled from the Coronavirus Aid, Relief, and Economic Security (CARES) Act in the 2020/21 Budget Act, tax practitioners have been asking how one reports a taxpayer’s income as required under the decoupling. This confusion arose because when the decoupling was enacted, no new Tax Law §§ 612(b) additions & 612(c) subtractions were enacted. However on Forms IT-201, IT-203, IT-204 and IT-205, taxpayers are still required to list the taxable items that comprise their taxable Federal adjusted gross income (AGI). Due to the decoupling from the CARES Act, these items may not be the same for New York.

  • Common Cryptocurrency Frauds

    By:
    Katerina L. Gaebel, CPA, CFE
    |
    Dec 1, 2020

    Bitcoin was first introduced to the world in 2009 after the global economic crisis. Bitcoin developers wanted to empower individuals to initiate online transactions that are anonymous, fast, irreversible, secure, and without the involvement of a third party. Although Bitcoin was not created to condone malicious conduct, fraudsters often use cryptocurrency because of its semi-anonymous nature.

  • Stuck in the Middle with You: The Rise of the Independent Sponsor in the Middle and Lower Middle Market

    By:
    Paul Marino, JD
    |
    Dec 1, 2020
    The independent sponsor (formerly known as “fundless sponsors”) is an equity sponsor that seeks to purchase (generally) privately held business with the backing of investors.  However, as opposed to private equity funds, independent sponsors do not have access to pooled cash reserves and therefore must seek investors on a deal-by-deal basis.

  • Remote Workers Beware: Potential Double Taxation Under the Convenience Rule

    By:
    Ariele R. Doolittle, Esq.
    |
    Nov 1, 2020

    As the realities of COVID-19 are setting in, telecommuting arrangements have emerged as part of the new normal. A recent study found that the vast majority of employers plan to allow their employees to work remotely at least part-time and nearly half will allow this full-time going forward. Remote workers utilizing new work locations can trigger state-level income tax consequences, which may include two states seeking to tax the same income.

  • Final Regulations Applying the High-Tax Exclusion to Global Intangible Low-Taxed Income

    By:
    Timothy Larson, CPA
    |
    Nov 1, 2020

    The IRS recently issued final and proposed IRC section 951A regulations relating to the treatment of “high-taxed” global intangible low-taxed income (GILTI), introduced in 2017 by the Tax Cuts and Jobs Act (TCJA). This latest guidance is welcome news to many U.S. investors, who may now make annual elections to exclude high-taxed GILTI from their gross income — both going forward and retroactively to 2018.
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