Upcoming National Meeting

2025 Spring Conference / Audit Session

This Spring Conference/Audit Session will bring multistate tax professionals, with various levels of experience in state and local income/franchise taxes and sales/use taxes together in an environment that allows for extensive interaction and exchange of information as well as updates on key SALT issues and insights regarding state tax trends and opportunities. The program is targeted to all level

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Newsletters & Media

Cost Conscious

ISSUE 25-01; January 17, 2025

Tracking State Tax Legislation [Part I] – Now that year-end close has wrapped up, many COST members are turning their attention to monitoring 2025 SALT legislation proposed by the states. What services do you use to help monitor state tax legislation? Choose all that apply.

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Bloomberg TAX

Trump Raised Millions From Crypto Firms for His Inauguration

January 30, 2025

President Donald Trump’s inaugural committee received millions of dollars in donations from firms in the cryptocurrency industry that’s already seeing special attention from his administration, disclosures filed with the Senate Office of Public Records show.

Canada May Delay Capital Gains Tax Increase: CBC

January 30, 2025

Canada’s Liberal government may delay implementing an increase to the capital gains inclusion rate, CBC News reported, citing unidentified sources.

Fox Rothschild Blocks DeepSeek’s AI Model for Attorney Use

January 30, 2025

Fox Rothschild LLP blocked its lawyers from accessing tools from DeepSeek, the Chinese artificial intelligence startup, citing concerns about the privacy risks it may pose to client data.

Marijuana Business Owner Stumbles in Constitutional Tax Appeal

January 30, 2025

An owner of a medical marijuana business convicted for tax crimes after failing to disclose that business to the IRS didn't properly raise a challenge to Congress's constitutional authority to tax marijuana, the Sixth Circuit said Thursday.

IRS PLR: Hovering Deficit Not Taken Into Account in Computing Undistributed Foreign Earnings (IRC §245A)

January 30, 2025

The IRS has published a private letter ruling on Section 245A concerning a proposed transaction, which is part of a single integrated plan, in which for a certain tax year: 1) controlled foreign corporations owned by a foreign subsidiary, a limited partnership electing to be classified as a corporation, will pay dividends to the foreign subsidiary; and 2) the foreign subsidiary will pay a dividend to a U.S. corporate subsidiary. The IRS ruled that the foreign subsidiary hovering deficit is not taken into account in computing the foreign subsidiary’s undistributed earnings and therefore, its undistributed foreign earnings, for purposes of Section 245A(c). [PLR 202504005]

NJ Bill Would Preserve Senior Property Tax Break When Downsizing

January 30, 2025

New Jersey lawmakers advanced bipartisan legislation allowing recipients of the Senior Freeze property tax relief program to keep their benefit when they downsize or relocate to a new home.

House Panel Presses IRS for Details About Rich Taxpayers Leak

January 30, 2025

The IRS must turn over more details on how many taxpayers had personal information exposed in an IRS contractor's leak of prominent billionaires' tax returns—including those of President Donald Trump, House Judiciary Committee Chair Jim Jordan (R-Ohio) said Thursday.

Pennsylvania Governor Revives Emissions Cap-and-Invest Proposal

January 30, 2025

Pennsylvania Gov. Josh Shapiro (D) is taking another stab at propping up a statewide program that would charge entities for their greenhouse gas emissions and cap those emissions over time.

IRS PLR: Rulings on Tax Consequences of Marital Trust Division (IRC §2056)

January 30, 2025

The IRS has published a letter ruling on Section 2056, concluding that: 1) the division of the Marital Trust into Trust 1 and Trust 2 on a non-pro rata basis will not cause recognition of income, gain, or loss under Sections 61 or 1001; 2) after the division, the Trusts will continue to be a qualified terminable interest property (QTIP) trusts under Section 2056(b)(7); 3) the taxpayer's disclaimer of her interest in Trust 1 will be treated as a disposition of her qualifying income interest in Trust 1 and a gift of all other interests in Trust 1, but will not cause any property in Trust 2 to be treated as a gift; 4) the value of Trust 1 transferred will not be included in the taxpayer's gross estate; and 5) the disclaimer will not cause the taxpayer's interest in Trust 2 to be valued at zero. [PLR 202504007]

IRS PLR: Rulings on Proposed Division of Marital Trust (IRC §61)

January 30, 2025

The IRS has published a private letter ruling on Sections 61, 1001, 2044, 2056, 2511, 2519, and 2702, regarding the treatment of trusts and beneficiaries after the proposed division of a marital trust. [PLR 202504006]

Featured Resources

COST - Council on State Taxation

Amicus Briefs

Amazon Services LLC v. Department of Revenue

On November 19 COST filed a motion for leave to file an amicus brief at the South Carolina Supreme Court in support of Amazon Services LLC. Amazon Services LLC v. Department of Revenue. The Court of Appeals held that the Amazon. Services was in the business of selling tangible personal property and thus responsible for collecting and remitting sales tax on third-party sales made from the Amazon m

COST - Council on State Taxation

COST Studies, Articles & Reports

FY23 State And Local Business Tax Burden Study

The Council On State Taxation (COST) and the State Tax Research Institute (STRI) are pleased to announce the release of our 22nd annual study of state and local business taxes. The report, “Total State and Local Business Taxes: State-by-State Estimates for Fiscal Year 2023,” prepared by Ernst & Young LLP, shows all state and local business taxes paid in each of the 50 states and the District of Co

COST - Council on State Taxation

COST Comments & Testimony

Testimony in Support of Virginia House Bill 2681 - NOL Calculation

On January 28, COST testified in support of H.B. 2681, which would direct the Virginia Department of Taxation to study and recommend improvements to NOL calculation requirements.