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Massachusetts DOR Explains 4% Surcharge on Individual Income in Excess of $1 Million
Massachusetts DOR Explains 4% Surcharge on Individual Income in Excess of $1 Million

FirenzeCapitalAdvisors
Dec 1, 20231 min read


Pennsylvania Supreme Court Affirms Philadelphia Validly Denied Wage Tax Credit for Taxes Paid
Pennsylvania Supreme Court Affirms Philadelphia Validly Denied Wage Tax Credit for Taxes Paid

FirenzeCapitalAdvisors
Dec 1, 20232 min read


California: Limited Time Resolution for Some Eligible Transactions Subject to NEST Penalty is Extend
FTB Notice 2023-03, Cal. Fran. Tax Bd. (11/13/23). The California Franchise Tax Board (FTB) issued FTB Notice 2023-03, which extends its...

FirenzeCapitalAdvisors
Nov 27, 20231 min read
IRS launches compliance initiatives targeting large businesses, high-wealth taxpayers
The US Internal Revenue Service (IRS) announced on 20 October 2023 that it has launched three new compliance programs—all funded with...

FirenzeCapitalAdvisors
Nov 1, 20238 min read
Texas: Guidance Addresses Costs Included as Benefits for Compensation Deduction for Franchise Tax
Letter No. 202310005L, Tex. Comptroller of Public Accounts (10/13/23). In a publication issued by Tax Policy explaining the types of...

FirenzeCapitalAdvisors
Oct 18, 20231 min read
Texas: Settlement Payment Deemed for Tort Damages and Thus Not Deductible as COGS for Franchise Tax
Case No. 13-21-00335-CV, Tex. Ct. App. (10/19/23). The Texas Thirteenth Court of Appeals (Corpus Christi – Edinburg) affirmed that an oil...

FirenzeCapitalAdvisors
Oct 17, 20231 min read
OECD Pillar One – Amount A Multilateral Convention
On October 11, 2023, the OECD published the “current consensus” of a multilateral convention for the implementation of Pillar One Amount...

FirenzeCapitalAdvisors
Oct 17, 20238 min read
Multistate Tax Commission Work Group Circulates Discussion Draft Model Rules on Guaranteed Payments
State Tax Sourcing of Guaranteed Payments for Services & Additional Credit for Taxes Paid to Other States Proposed Models – Discussion...

FirenzeCapitalAdvisors
Oct 14, 20231 min read
Multistate Tax Commission Work Group Circulates Discussion Draft Model Rules on Guaranteed Payments
State Tax Sourcing of Guaranteed Payments for Services & Additional Credit for Taxes Paid to Other States Proposed Models – Discussion...

FirenzeCapitalAdvisors
Oct 14, 20231 min read
Pennsylvania: Updated Bulletin Addresses How IRC §163(j) Limitations are Treated for State Corporate
Corporation Tax Bulletin 2019-03: Pennsylvania Corporate Net Income Tax Treatment of IRC § 163(j), Pa. Dept. of Rev. (rev. 10/12/23). The...

FirenzeCapitalAdvisors
Oct 13, 20232 min read
New Jersey: New and Updated Bulletins Reflect CBT Law Changes Involving Gross Income Tax, NOLs, and
Tax Bulletin No. TB-112: Gross Income Tax Allocation and Uniformity with Corporation Business Tax Sourcing for Receipts Business Income,...

FirenzeCapitalAdvisors
Oct 12, 20232 min read
Massachusetts DOR Explains 4% Personal Income Surtax on Taxable Income Over $1 Million
4% Surtax on Taxable Income Over $1,000,000,The Massachusetts Department of Revenue (Department) posted implementation guidance...

FirenzeCapitalAdvisors
Oct 11, 20231 min read
Massachusetts: New Law Contains Significant Tax Law Changes Including Single Sales Factor Adoption
H.B. 4104, signed by gov. 10/4/23. Effective for tax years beginning on or after January 1, 2025, new law adopts single sales factor...

FirenzeCapitalAdvisors
Oct 4, 20231 min read
North Carolina DOR Explains New Law Expanding Eligibility for Pass-Through Entity Tax Election
The North Carolina Department of Revenue issued partnership tax guidance addressing recently enacted legislation that, among other tax...

FirenzeCapitalAdvisors
Oct 4, 20231 min read
Florida Circuit Court Holds that Intercompany Sales of Electronically Delivered Software are Not Tax
Case No. 2021-CA-000206, Fla. Cir. Ct., Leon County (9/27/23). In a case involving electronically delivered software sold by a...

FirenzeCapitalAdvisors
Sep 29, 20231 min read
North Carolina: Ruling Addresses Market-Based Sourcing of Receipts from Contract Manufacturing
CPLR 2023-02, N.C. Dept. of Rev. (6/20/23). In a private letter ruling involving a company providing contract manufacturing services to...

FirenzeCapitalAdvisors
Sep 28, 20231 min read
European Commission publishes proposed directive on head office tax system for SMEs
n 12 September 2023, the European Commission (“Commission”) published a proposal for a directive establishing a head office tax (HOT)...

FirenzeCapitalAdvisors
Sep 20, 20234 min read
European Commission proposes BEFIT as new EU-wide corporate tax base
On 12 September 2023, the European Commission (“the Commission”) published its long-awaited proposal for a directive introducing a common...

FirenzeCapitalAdvisors
Sep 15, 20239 min read
New Jersey: New and Updated Bulletins Reflect CBT Law Changes Involving GILTI, FDII, and Combined Re
Tax Bulletin No. TB-110: Corporation Business Tax GILTI Treatment for Privilege Periods Ending on and After July 30, 2023, N.J. Div. of...

FirenzeCapitalAdvisors
Sep 13, 20232 min read
New Jersey: New and Updated Bulletins Reflect CBT Law Changes Involving Nexus and Combined Reporting
Tax Bulletin No. TB-108: Nexus for Corporation Business Tax for Privilege Periods Ending on and after July 31, 2023, N.J. Div. of Tax....

FirenzeCapitalAdvisors
Sep 8, 20232 min read
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