Upcoming National Meeting

2024 SALT Workshop for Technology Companies

This Workshop will cover the key state and local tax issues that technology companies (both start-up and established) are facing such as state taxation of Digital Business Inputs, FITFA, sourcing, apportionment, streaming, marketplace facilitators, digital service taxes and much more. Leading state tax experts will share technical expertise and knowledge they have gained from practicing in these

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Newsletters & Media

Legislative Alert

ISSUE 24-28; July 16, 2024

COST Joins Coalition Letter Expressing Opposition to Revised DC Data Excise Tax Proposal; Advocacy Efforts Against Oregon Initiative to Increase Corporate Minimum Tax

Cost Conscious

ISSUE 24-15; July 26, 2024

Navigating Audit Adjustments Under Pennsylvania’s Addback Statute – Since January 2015, the Pennsylvania Department of Revenue has had the authority to disallow deductions against the corporate net income tax for royalties, licensing, or other fees paid to an affiliated entity including interest expense if it was related to an intangible expense or cost. In general, related-party intangible expens

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Bloomberg TAX

Investors Sue IRS Over Nixed $93 Million Easement Deduction

July 26, 2024

A Florida investment firm urged the US Tax Court to review whether the IRS should have disallowed a $93 million conservation easement donation tax deduction, arguing that they properly relied on experts to determine the land's value.

US Sues Tax Plan Salesmen for Possible $130 Million Revenue Loss

July 26, 2024

The US sued pair of tax strategy salesmen on Friday to block them from selling a scheme that allegedly encourages small businesses to take unlawful deductions.

Michigan Taxpayers Ask Justices to Review Foreclosure Sale Issue

July 26, 2024

Michigan's procedure for claiming surplus proceeds from tax foreclosure sales violates the US Constitution’s takings clause, two property owners told the state's Supreme Court.

State of Tax: JetBlue Sues Florida, Nebraska Starts Debate

July 26, 2024

The week in state tax: JetBlue Airways alleges Florida's corporate income tax calculation method unconstitutionally makes airlines count miles flown well outside the state's boundaries. Meanwhile, Nebraska lawmakers tackle the governor's tax overhaul plan and a number of their own proposals, a power purchase agreement must be weighed as a factor in Mesquite Power's property tax valuation in Arizona, and Verizon can't get a borough tax refund in New Jersey.

Ex-EY Global Head Behind Failed Split Joins Consello as Advisor

July 26, 2024

The Consello Group appointed former Ernst & Young global chair Carmine Di Sibio as a senior advisor to the firm Friday. Di Sibio retired in June after leading a failed bid to split the $50 billion audit and consulting firm.

Direct File Deputy Moves to Senior Adviser Role to IRS Chief

July 26, 2024

Merici Vinton, former Direct File deputy, is starting a new role as a senior adviser for digital delivery to the IRS commissioner, the agency confirmed Friday.

Rubbermaid Parent Brings $124 Million Transfer Pricing Tax Suit

July 26, 2024

Newell Brands Inc., the multi-billion dollar consumer products manufacturer behind Rubbermaid, Yankee Candle and Sharpie, sued the US government to challenge its alleged $124 million tax debt.

US Business Group Challenges Global Minimum Tax in Belgium

July 26, 2024

The American Free Enterprise Chamber of Commerce is mounting a legal challenge to an EU directive requiring all the bloc's member states to apply the global minimum tax rules.

IRS PLR: Extension Granted to Make Corporation Tax Classification Election (IRC §7701)

July 26, 2024

The IRS has published a private letter ruling on Treasury Regulation Sections 301.7701 and 301.9100, granting a foreign entity an extension of time to elect to be classified as an association taxable as a corporation for federal tax purposes. [PLR 202430004]

IRS PLR: Extension Granted to Make Corporation Tax Classification Election (IRC §7701)

July 26, 2024

The IRS has published a private letter ruling on Treasury Regulation Sections 301.7701 and 301.9100, granting a foreign entity an extension of time to elect to be classified as an association taxable as a corporation for federal tax purposes. [PLR 202430001]

Featured Resources

COST - Council on State Taxation

Amicus Briefs

Dine Brands Global, Inc. V. Eubanks and The Walt Disney Company v. Eubanks

COST filed an amicus brief on June 14 asking the Michigan Supreme Court to affirm the decision of the Court of Appeals in Dine Brands Global, Inc. V. Eubanks and The Walt Disney Company v. Eubanks, where the court held an examination or audit conducted by the Treasurer was not an “action or proceeding” under the Michigan Unclaimed Property Act and did not toll the statute of limitations

COST - Council on State Taxation

COST Studies, Articles & Reports

COST - Council on State Taxation

COST Comments & Testimony

Joint Letter in Opposition to TRC’s Consideration of a Data Excise Tax

COST again joined a coalition letter in strong opposition to DC Tax Reform Commission’s continued consideration of a data excise tax.