Public Law 86-272 has long been used to protect out-of-state businesses from being taxed on net income earned in other states if the only business activity of the company within the other states consists of the solicitation of orders for sales of tangible personal...
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Multi-state Tax Issues
PPP and EIDL Loan Fraud
When it comes to PPP and EIDL fraud, the government has more time to make its case against defendants. In August 2022, the statute of limitations to bring charges against a defendant for fraud under the Paycheck Protection Program (PPP) or Economic Injury Disaster...
Biden’s FY2023 Budget Proposal Includes Increase to Estate and Gift Tax, and Higher Individual and Corporate Income Taxes
President Biden recently released his FY2023 Budget, and the U.S. Treasury provided details regarding the related revenue provisions. The proposal includes increased income tax for individuals from a top rate of 37% to 39.6%, and for C corporations from 21% to 28%....
New IRS Division Announced — Tax Scheme Promoters Beware
The Office of Promoter Investigations (OPI) was announced yesterday as the IRS’ latest division targeting compliance issues. OPI will focus on those individuals who promote and peddle tax fraud and tax avoidance schemes. Before the creation of OPI, the IRS’ Small...
California Provides Nexus Relief
What happens when an out-of-state business suddenly has an employee working from home in California due to COVID-19, and in accordance with Governor Newson’s Executive Order N-33-20, the “Stay at Home” Order? A corporation may be concerned that while it had no...
Proposed Multi-State Worker Tax Fairness Act of 2020 (H.R. 7968)
The ”convenience of the employer” test has long been used to allow states to tax nonresident workers who are physically present in a state for work performed in the taxing state. In August, H.R. 7968 was introduced which would limit a State's ability to tax wages...
Update to PL 86-272
Public Law 86-272 has long been an income tax protection for out-of-state sellers who enter into other states, including California, for purposes limited to the “mere solicitation of orders” of tangible personal property, when the orders are approved and filled...