Upcoming National Meeting

2024 Forum on U.S. State and Local Taxes for European Companies (London)

1 day conference on U.S. State and Local Taxes for European companies. Leading practitioners with dedicated knowledge in this area will help attendees understand the tax requirements and risks of doing business or expanding into the vastly lucrative U.S. market. Differences between the U.S. and European tax systems will be covered and attendees will learn about threshold issues such as nexus an

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Newsletters & Media

Legislative Alert

ISSUE 24-08; February 27, 2024

COST Opposes Mandatory Worldwide Combined Reporting in Maryland; COST Urges New Mexico Governor to Line-Item Veto Foreign Source Income Provisions in Tax Omnibus Bill

Cost Conscious

ISSUE 24-04; February 23, 2024

Monetary Threshold for Imposing Sales Tax Collection Obligation – After the U.S. Supreme Court’s Wayfair decision, all states with a general sales tax now impose a collection responsibility on remote sellers that uses, at least in part, a monetary sales threshold. The sales used to calculate the threshold differ among the states but fall within one of three buckets: 1) gross sales, which includes

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Bloomberg TAX

Corporate Transparency Act Is Unconstitutional, Judge Rules

March 02, 2024

A federal court in Alabama has ruled that a law requiring companies to report extensive stakeholder ownership information to the government is unconstitutional.

World Trade Chiefs Pull Talks From Brink With E-Commerce Deal

March 02, 2024

The World Trade Organization agreed to extend a moratorium on e-commerce tariffs for two years after marathon negotiations in Abu Dhabi, while failing to secure deals on other contentious trade issues including a crackdown on agriculture and fisheries subsidies.

Doctor Receives 52 Months in Prison for Decade-Long Tax Evasion

March 01, 2024

A physician and owner of an urgent care clinic has been sentenced to 52 months in prison for tax evasion, according to the Department of Justice Friday.

IRS PLR: Incentive Payments Made Under Program Are Excludable from Recipient’s Gross Income, Taxpayer Not Required to Report (IRC §61)

March 01, 2024

The IRS has published a private letter ruling on Sections 61 and 6041, regarding whether incentive payments made under a program to or on behalf of eligible recipients are excludable from their gross income. [PLR 202409013]

IRS PLR: Incentive Payments Made Under Program Are Excludable from Recipient’s Gross Income, Taxpayer Not Required to Report (IRC §61)

March 01, 2024

The IRS has published a private letter ruling on Sections 61 and 6041, regarding whether incentive payments made under a program to or on behalf of eligible recipients are excludable from their gross income. [PLR 202409011]

IRS PLR: Incentive Payments Made Under Program Are Excludable from Recipient’s Gross Income, Taxpayer Not Required to Report (IRC §61)

March 01, 2024

The IRS has published a private letter ruling on Sections 61 and 6041, regarding whether incentive payments made under a program to or on behalf of eligible recipients are excludable from their gross income. [PLR 202409009]

IRS PLR: Extension Granted to File “Portability” Election (IRC §2010)

March 01, 2024

The IRS has published a private letter ruling on Section 2010 and Treasury Regulation Section 301.9100 granting 120-day extension to file Form 706 to make “portability” election of decedent spouse’s unused exclusion (DSUE) amount. [PLR 202409015]

IRS PLR: Incentive Payments Made Under Program Are Excludable from Recipient’s Gross Income, Taxpayer Not Required to Report (IRC §61)

March 01, 2024

The IRS has published a private letter ruling on Sections 61 and 6041, regarding whether incentive payments made under a program to or on behalf of eligible recipients are excludable from their gross income. [PLR 202409010]

IRS PLR: REIT’s Right to Receive Brownfield Credits Deemed a Receivable Under GAAP, Income Attributable to Receipt or Accrual of Credits is Qualifying Income (IRC §856)

March 01, 2024

The IRS has published a private letter ruling on Section 856 regarding GAAP classification and tax treatment of real estate investment trust’s (REIT’s) right to receive Brownfield Credits. [PLR 202409002]

IRS PLR: Incentive Payments Deemed Excludable from Gross Income, Not Subject to Information Reporting Requirements (IRC §61)

March 01, 2024

The IRS has published a private letter ruling on Sections 61 and 6041 regarding gross income tax treatment and information reporting requirement of payments issued to eligible participants of government incentive program. [PLR 202409012]

Featured Resources

COST - Council on State Taxation

Amicus Briefs

Olympic and Georgia Partners, LLC v County of Los Angeles

COST filed an amicus brief in a California property tax case addressing the exclusion of certain intangible values in a hotel’s valuation that is pending before the Supreme Court of California. COST’s brief addresses a cost reimbursement provided by the City of Los Angeles and why that income should be excluded as an intangible value when capitalizing the income stream of the property. Issues with

COST - Council on State Taxation

COST Studies, Articles & Reports

COST Scorecard: The Best and Worst of State Tax Administration (2023)

The Council On State Taxation (COST) is pleased to release its 2023 Scorecard on state tax appeals processes and administrative practices. This eighth Administrative Scorecard continues to apply objective criteria to evaluate independence in tax appeals systems and key procedural elements that impact taxpayers’ perceptions of fairness and efficiency.

COST - Council on State Taxation

COST Comments & Testimony

Letter in Opposition to Vermont's Efforts to Impose Mandatory Worldwide Combined Reporting

COST submitted this letter to the Vermont Committee on Ways and Means expressing COST’s opposition to the committee’s efforts to repeal the “water’s-edge” provision in Vermont’s corporate income tax statute and impose a mandatory worldwide unitary combined reporting tax scheme on Vermont’s corporate taxpayers.