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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


Nevada: Credit Card Processing Fee Included on Invoice of Taxable Sale is Subject to Sales Tax
Nevada Tax Notes: Issue No. 197, Nev. Dept. of Tax. (10/23). In its recent newsletter, the Nevada Department of Taxation (Department)...

FirenzeCapitalAdvisors
Nov 21, 20231 min read


New Jersey Division of Taxation Addresses “Convenience of the Employer” Rule for Nonresidents Who Ne
Convenience of the Employer Sourcing Rule FAQs, N.J. Div. of Tax. (10/27/23). The New Jersey Division of Taxation (Division) issued some...

FirenzeCapitalAdvisors
Nov 2, 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


British Virgin Islands removed from EU list of noncooperative jurisdictions
On 17 October 2023, the Council of the European Union issued a press release advising of the removal of the British Virgin Islands (BVI)...

FirenzeCapitalAdvisors
Oct 19, 20231 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
Pennsylvania: City of Philadelphia DOR Explains Wage Tax Application for Remote and Hybrid Work
Wage Tax policy guidance for non-resident employees (UPDATED), City of Philadelphia, Penn. Dept. of Rev. (10/12/23). The City of...

FirenzeCapitalAdvisors
Oct 16, 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
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
Services for Online Creators
We identified many years ago that online content creator platforms were increasingly gaining new users so we designed a business package...

FirenzeCapitalAdvisors
Oct 12, 20231 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
New Jersey Division of Taxation Explains New Refundable Credit
Refundable Gross Income Tax Credit for New Jersey Residents Who Successfully Challenge Another State’s Imposition of the Convenience of...

FirenzeCapitalAdvisors
Sep 29, 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
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