State and local tax services

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State and local tax services

For many companies, a large percentage of their overall tax liability comes from state and local taxes. With various taxing jurisdictions becoming ever more aggressive, the puzzle of multistate issues can “tax” a company’s internal resources and drain its profits. The desire for unbiased tax advice is at a premium. Grant Thornton’s state and local tax professionals stand ready to fill that role.

California Franchise Tax Board confirms taxpayer subject to special franchisor apportionment rule

The California Franchise Tax Board recently issued Chief Counsel Ruling 2010-2 concluding that a taxpayer receiving license fees and royalties from its foreign affiliates and unrelated third parties is a “franchisor” subject to the special franchisor apportionment rules. It also determined that because the taxpayer made a water’s-edge election, the taxpayer’s license fees and royalties from its foreign affiliates should be treated in the same manner as payments from third-party licensees.

Oregon Tax Court holds gain from sale of essential FCC license constituted business income

The Oregon Tax Court held that gain from the sale of a federal license that allowed the operation of cellular communications systems in rural areas of the state was business income for purposes of applying the apportionment provisions. According to the Tax Court, gain on the sale of assets used in a business is subject to apportionment without regard to whether the gain results from a liquidation of the business. The Tax Court also discussed the activities to be considered in the cost of performance calculation required for sales of property other than tangible personal property, but did not determine how much of the sale should be apportioned to Oregon.

New York enacts budget legislation containing variety of state tax provisions

The budget legislation extends the captive real estate investment trust (REIT) and captive regulated investment company (RIC) provisions that were enacted in 2008 and amends the captive REIT definition. In addition to temporarily deferring many tax credits, the legislation amends the biofuel production credit, the qualified emerging technology company credit and the Empire Zone credits. For purposes of the personal income tax, the legislation limits the itemized deductions for high-income taxpayers, amends the provisions concerning New York source income for nonresidents and creates a new tax bracket for high-income taxpayers in New York City. And more...

Manage your tax burden with local resources and national expertise

Planning for and complying with state and local tax law requires a strategy tailored to your company. Download a quick summary of the services Grant Thornton can offer to help you decrease your effective tax rate, align your tax and business planning, identify nonstructural tax savings and more.

This website supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the subject of this document we encourage you to contact us or an independent tax advisor to discuss the potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this document may be considered to contain written tax advice, any written advice contained in, forwarded with, or attached to this document is not intended by Grant Thornton to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.