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Newsletters & Media

Cost Conscious

ISSUE 17-23; November 17, 2017

Auditor Evaluations – COST’s primary purpose in fostering dialogue with state tax administrators (and issuing Administrative Scorecards) is to encourage states to transform the auditor/taxpayer relationship from a strictly adversarial approach to a more customer-focused business model. In this vein, we encourage the establishment of Commissioner Advisory Groups and frequently reach out to administ

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Bloomberg BNA

Will Goodlatte’s Retirement Lead to Federal Digital Tax Solution?

 

It’s not certain that Rep. Bob Goodlatte’s (R-Va.) retirement will open the door to long-awaited federal legislation addressing states’ taxing authority over remote retailers.

Will Multiple Briefs Sway Supreme Court to Take Digital Tax Case?

 

The U.S. Supreme Court has dozens of state attorneys general and interest groups knocking on its door to take up the issue of states’ taxing authority over remote retailers.

House GOP Tax Plan Draws Protests Over State Impact

 

Federal lawmakers and groups representing state and local governments are pushing back against a key deduction contained in the House Republican tax reform plan released Nov. 2.

Wave of Amazon HQ2 Bids Unlike Anything Experts Have Seen

 

Is the nationwide tidal wave of proposals for Amazon’s second headquarters an unprecedented incentive bonanza, a game-changer, or a PR-stunt precipitating a dozen more PR stunts?

Reworking Intercompany Loan Rules a Mixed Blessing for States

 

Treasury Department recommendations to simplify Obama-administration documentation requirements on intercompany lending may be good news and bad news for states deciding whether to conform.

First Digital Sales Tax Dispute Reaches U.S. Supreme Court

 

South Dakota’s Attorney General has filed the first of an expected wave of state petitions asking the U.S. Supreme Court to reconsider a 25-year-old opinion restricting states’ ability to tax remote retailers.

State Groups Vow Fight for Tax Deduction Despite Trump, Big Six

 

Groups representing state and local officials will lobby hard to persuade members of Congress not to go along with calls from President Donald Trump and GOP leaders to end the federal deduction for...

States Won’t Sweat Conformity to Retroactive Tax Reform

 

States that want to follow retroactive provisions of whatever tax reform package comes from Congress this year probably wouldn’t worry about legal challenges.

Federal Partnership Rules May Be Tricky for States: ABA Group

 

State and local governments may find themselves in a pickle when a new federal partnership audit regime goes into effect, according to a Sept. 11 letter addressed to Internal Revenue Service...

First U.S. Prosecution Over ‘Zapper’ Software Nets Guilty Plea

 

A Seattle-area restaurant owner accused of using software to hide receipts and steal sales tax revenue pleaded guilty Aug. 30 in the first such prosecution in the U.S., the Washington Attorney...

IRS Asked to Help States by Clarifying Partnership Audit Regime

 

An influential tax group is asking the IRS to clarify how proposed regulations will implement certain aspects of the new federal partnership audit regime.

Michigan’s Value-Added Tax: A Cautionary Tale for Feds, States

 

The U.S. has been among a small number of developed countries for most of the last century in resisting an academically revered economic policy—the value-added tax. Michigan’s failed VAT may help...

‘Looking at You, Kid': Tax Credits for Movies, TV in Focus

 

The stiff competition among states to lure the multibillion-dollar film and television industry with lucrative tax credits may be going through a Darwinian period where only the strongest survive.

State Deduction Needed for Tax Reform After Health Care Failure

 

Republicans’ failure to repeal the taxes underlying the Affordable Care Act makes eliminating the deduction for state and local taxes even more important to their tax reform plans.

Federal Tax Reform Driving States to Digital Sales Taxes

 

Federal lawmakers’ efforts to control states’ taxing authority over remote retailers is adding pressure as potential federal tax reform threatens to further deplete states’ coffers.

Federal Bills Fighting to Modernize Interstate Taxes

 

A House-passed bill standardizing rules for taxing nonresident workers will face stiff opposition from large states that stand to lose millions in revenue, an original co-sponsor of the Senate...

Businesses Face a Patchwork of Trade Show Tax Rules

 

Businesses that use trade shows to promote and sell their products would be well-advised to research the hosting state’s nexus rules if they hope to avoid long-term sales and use tax duties in that jurisdiction, tax practitioners told Bloomberg BNA.

Prolific Tax Whistle-Blower Must Rethink Strategy

 

A Chicago lawyer regarded as the most prolific tax whistle-blower in the U.S. will have to reconsider his relentless litigation strategy in light of a state appeals court finding him ineligible for...

IRS Releases Proposed Partnership Audit Rules After Delay

 

The IRS proposed rules to implement the new partnership audit regime after a regulatory freeze delayed release of the guidance for five months.

Parties Unveil Model State Statute for Partnership Audit Law

 

Practitioners have rolled out draft model legislation that many hope will serve as the starting point for uniform state statutes addressing the new federal partnership audit regime.

States No Longer Fretting Over Federal Tax Reform This Year

 

The pressure to go into special session or take immediate action this year in response to federal tax reform no longer exists for state lawmakers and governors

Gray Areas in State Tax Policies: Bloomberg BNA Survey

 

Lawmakers’ strategy to strike a decades-old, state-border restriction on taxing sales may prove fruitful before the U.S. Supreme Court, according to a leading state and local tax practitioner.

States Eye New York Whistle-Blower Law as Tax Fraud Tool

 

State lawmakers and tax administrators are taking a closer look at enacting whistle-blower statutes as a strategy for prosecuting big-ticket incidents of tax fraud and scooping revenue into state coffers.

Tax Reform Would Send States Back to ‘Drawing Board’

 

Most modifications materializing from a potential federal tax reform package would throw states’ personal and corporate income tax structures up in the air, according to a leading tax professional.

States to Battle White House for Tax Deduction, Muni Exemption

 

States and cities are fighting to preserve a deduction for taxes paid to local governments after the White House’s tax plan said it would jettison the popular tool.

States, Tax Groups Furiously Planning for Partnership Audit Law

 

States and taxpayers aren’t waiting for a fix to the new federal partnership audit regime as they wade further into it to assess how the law will shape state tax systems.

Carried-Interest Bill Gets Attention in Connecticut

 

A subcommittee in the Connecticut Legislature heard testimony April 11 from the group called Patriotic Millionaires on a bill that would end the carried-interest tax advantage that benefits...

Digital Sales Tax: Hit and Miss in States

 

States’ collective agenda to rope in lost revenue from remote sales has yielded mixed results so far in 2017.

Most States Sick Over GOP Health Bill, Impact on Budgets

 

Rick Noonan said he wanted to cry when he heard the American Health Care Act was getting closer to becoming law.

Rise of Machines to Spark Rise of San Francisco Taxes?

 

Whether San Francisco should adopt an automation tax to replace taxes lost to automated jobs is the subject of a hearing proposed by a supervisor backing CEO pay surcharges.

Online Sales Tax Marching Toward South Dakota High Court

 

The South Dakota Supreme Court could soon take up the state’s online sales tax that a lower court ruled unconstitutional.

End of An Era: State Tax Legend Paul Frankel Dies

 

A light has gone out in the state and local tax world with the passing of one of its most preeminent and beloved practitioners.

Kansas Passthrough Exemption on Life Support

 

A controversial income tax break came back from the dead in the Kansas Legislature Feb. 22, but it appears to have little chance of ultimately surviving the current legislative session.

Business Tax Burdens Possibly on States’ Chopping Block

 

State efforts to carve out business personal property from taxation are gaining steam amid continuing calls for states to remove business inputs from the sales tax base.

Import-Export Tax Idea Presents State Constitutional Pitfalls

 

States could run afoul of the Constitution by following a federal border-adjustments plan advocated by House Speaker Paul Ryan (R-Wisc.) to tax imports and exempt exports.

Trump’s High Court Pick May Shadow Scalia in State Tax Cases

 

Justice Antonin Scalia’s potential successor may be cut from a similar judicial cloth—but it remains to be seen how the Supreme Court nominee could shape state tax issues.

“High” Taxes—States Continue to Look to Marijuana to Generate Revenue

 

As Colorado and Washington continue to experiment with legalized marijuana, state lawmakers’ attention has turned to preserving the new revenues and tweaking tax provisions. Meanwhile, at least nine...

Taxation of LPs and LLCs: Variances Among States Pose Traps for the Unwary

 

Two of the most popular business structures for small business owners are limited liability companies (LLCs) and limited partnerships (LPs). These business entities offer a host of practical...

Corporate Close-Up: Five Things to Watch for in State Corporate Income Taxes in 2017

 

In Chinese astrology, 2016 is the year of the monkey, a symbol of mobility and action, apt for a year setting the stage for potentially massive tax overhauls. The coming year will be symbolized by...

Three Prominent State and Local Tax Practitioners' Outlook on What's Ahead in 2017

 

Bloomberg BNA recently asked three prominent state and local tax thought leaders about changes they see on the horizon for 2017. Below are the responses from EY's Joe Huddleston, KPMG's Harley Duncan...

Alabama to Push Online Tax Bill After High Court Clears Way

 

Alabama’s tax commissioner said she will ask the state Legislature to consider a Colorado-style reporting and notice requirement for out-of-state retailers that don’t collect and remit the state’s...

Comcast Scores Partial Win in California Tax Dispute

 

A California appellate court panel affirmed a trial court ruling that was a partial win for both Comcast and the Franchise Tax Board in a dispute about Comcast’s unitary ties with another company and...

Featured Resources

COST - Council on State Taxation

Amicus Briefs

Rent-A-Center West, Inc., v. South Carolina Department of Revenue

Amicus brief filed to inform the South Carolina Supreme Court it did not need to review this alternative apportionment case.

COST - Council on State Taxation

COST Studies, Articles & Reports

2017 State and Local Amnesty Programs

This report tracks state and local tax amnesty programs by state for 2017.

COST - Council on State Taxation

COST Comments & Testimony

Finance Committee Approves Tax Reform Bill – The Senate Finance Committee on November 16 approved by a vote of 14 to 12 a Senate version of tax reform legislation. The Finance Committee action comes after the House of Representatives on November 16 voted 227 to 205 to pass the ‘Tax Cuts and Jobs Act’ (HR 1). Pam Olson, Rohit Kumar, Scott McCandless, Todd Metcalf, Larry Campbell, Don Carlson, Janice Mays, Andrew Prior, Drew Lyon, Peter Merrill and Jon Lieber, PricewaterhouseCoopers LLP, November 17, 2017. Full House, Senate Committee, Pass Two Versions of Tax Reform – Focus of Tax Reform Shifts to Senate Floor as New Issues Emerge – On Nov. 16, the House passed its tax reform legislation H.R. 1, the Tax Cuts and Jobs Act, by a vote of 227 to 205 largely along party lines. In-depth coverage of the House bill can be found in our prior tax alerts. The same day, the Senate Finance Committee approved its different version of tax reform by a strict party-line vote. While this ‘train’ seems to be speeding along, some of the differences and emerging issues may conjure the image of two ‘runaway trains’ headed towards each other on the same track. Don Susswein, Kyle Brown and Rob Alinsky, RSM US LLP, November 17, 2017. Tax Reform Clears House; Finance Bill Headed to Senate Floor – Congressional Republican efforts to rewrite the federal tax code took a significant step forward on November 16 as the House of Representatives approved its version of comprehensive tax reform legislation and the Senate Finance Committee reported out a competing measure. Michael DeHoff, Jacob Puhl, and Storme Sixeas, Deloitte Tax LLP, November 17, 2017. House and Senate Bills Differ on Major Items – The House and Senate are headed towards a conference or other mechanism to reconcile their competing visions for tax reform. The House bill has passed the full House, and the Senate bill has been approved by the Senate Finance Committee, with further amendments possible on the Senate floor. As it stands now, here are the major differences–in terms of politics and revenue considerations–between the House bill and the plan approved on a conceptual level by the Senate Finance Committee. Note that in addition to the possibility of Senate floor amendments, the actual legislative text of the concepts approved by the Senate Finance Committee is not yet available. Don Susswein and Rob Alinsky, November 17, 2017. Private Activity Bond Provisions Face Elimination in House Tax Bill – House Tax Reform Bill (H.R. 1), the Tax Cuts and Jobs Act, was released on Nov. 2, 2017. One suggested tax law change that may have come as a surprise is in the area of private activity bonds issued after Dec. 31, 2017, and their favorable treatment under current tax laws. The suggested change comes in the form of a full repeal of the provisions that provide for the favorable tax treatment of interest income from such investments for federal income tax purposes. Specific provisions facing repeal are set forth in the following paragraphs. James Sweeney, RSM US LLP, November 17, 2017. Advance Refundings Face Repeal in Tax Reform Proposals – The race to tax reform has begun. Both the House and the Senate have their respective proposals documented and ready for markup ahead of an ultimate vote before both chambers of Congress. An area that caught many by surprise is a provision related to tax-exempt bond refundings not continuing to receive favorable tax exempt interest treatment. The House version of the tax reform package repeals private activity bond interest income from favorable tax-exempt treatment going forward for new issues. This provision is not present in the Senate Committee’s plan. However, refundings of bond issues also appears in the cross-hairs of the proposed plans from both the House and the Senate. The following are the provisions that will be stricken from tax law if passed. James Sweeney, RSM US LLP, November 17, 2017. House Passes Tax Reform Bill; Senate Finance Committee Considers Bill of Its Own – On November 9, 2017, the Senate Finance Committee released its version of proposed tax reform legislation, the “Tax Cuts and Jobs Act,” which the Committee is marking up this week. The House of Representatives passed its tax bill on November 16; however, the bill under consideration by the Senate Finance Committee differs in several respects, including individual tax rates, itemized deductions, retaining the estate and GST taxes, the timing of changes to the corporate tax rate, and pass-through tax rates. On November 14, 2017, Finance Chairman Hatch announced some changes to the Chairman’s Mark. One modification now would reduce the Patient Protection and Affordable Care Act individual mandate payment to zero. There are also other changes to rates, the child tax credit, the pass-through provisions, and international tax. Todd Simmens, Ben Willis, Joe Callianno and John Nuckolls, BDO USA LLP, November 17, 2017. A Comparison of the Energy Tax Changes in the Proposed House and Senate Tax Reform Bills – On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a Description of the Chairman’s Modification to the Chairman’s Mark of the “Tax Cuts and Jobs Act,” both prepared by the Joint Committee on Taxation (the Senate Plan). The Senate Plan, like the parallel Tax Cuts and Jobs Act under consideration in the House of Representatives (the House Plan), is far reaching and contemplates significant changes to how the US would tax individuals, domestic businesses and multinational businesses, including companies in the energy sector. This alert summarizes the principal proposals in the Senate Plan that impact the energy sector and notes meaningful differences from the House Plan. Eversheds Sutherland (US) LLP, November 16, 2017. Reconciling the Differences, the Senate Tax Cuts and Jobs Act – On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a Description of the Chairman’s Modification to the Chairman’s Mark of the “Tax Cuts and Jobs Act,” both prepared by the Joint Committee on Taxation (the Senate Plan). Eversheds Sutherland (US) LLP, November 16, 2017. House Passes Tax Reform Bill – The US House of Representatives on November 16 voted 227 to 205 to pass the ‘Tax Cuts and Jobs Act’ (HR 1). There were 13 Republicans who voted against the legislation. The bill proposes to lower business and individual tax rates, modernize US international tax rules, and simplify the tax law, with significant impacts on numerous sectors of the economy. Pam Olson, Rohit Kumar, Scott McCandless, Todd Metcalf, Larry Campbell, Don Carlson, Janice Mays, Andrew Prior, Drew Lyon, Peter Merrill and Jon Lieber, PricewaterhouseCoopers LLP, November 16, 2017. Senate Finance Plan Would Limit Deductions for ‘Active’ Tax Losses – Major Rewrite of Loss Rules for Entrepreneurs and Investors – The pending Senate tax reform plan–announced on Nov. 9, 2017–contains an obscure provision that could have dramatic effects on entrepreneurs and investors in small or startup businesses. It could also dramatically affect real estate professionals who deduct active real estate losses against active real estate professional income. Don Susswein, November 15, 2017. Senate Liberalizes Pass-Through Rate Proposal – Chairman’s Proposed Revisions Would Help Service Businesses – On Nov.14, Chairman Orrin G. Hatch of the Senate Committee on Finance released an updated Chairman’s Mark of the Tax Cuts and Jobs Act which, in part, makes changes to the treatment of pass-through entities. Don Susswein, RSM US LLP, November 15, 2017. Exempt Organization Provisions in the Senate Tax Reform Proposal - Proposed Tax Changes that Could Affect Tax-Exempt Organizations – On Nov. 9, 2017, the Senate Committee on Finance released its version of the Tax Cuts and Jobs Act following the release of the House proposal. This article provides the proposed tax changes that could affect tax-exempt organizations. James Sweeney, RSM US LLP, November 14, 2017. Hatch Unveils Modifications to Tax Cuts and Jobs Act – Senate Finance Committee Chairman Orrin Hatch, R-Utah, released a modified version of his Tax Cuts and Jobs Act November 14 that calls for significant new revenue offsets as well as proposals to pare back some of the tax relief provisions included in the measure as originally introduced. Alex Brosseau, Michael DeHoff and Jacob Puhl, Deloitte Tax LLP, November 14, 2017. The U.S. House Ways and Means Committee Passes Tax Cuts and Jobs Act – The largest effort in a generation to rewrite the U.S. tax code are moving at an accelerated pace in both chambers of the U.S. Congress. The House Ways and Means Committee passed H.R. 1, The Tax Cuts and Jobs Act, on November 9th to conclude a four-day markup. The bill passed along a pure party line vote with the Republican majority providing a 24-16 margin to advance the bill to the House floor, where debate and passage will occur on Thursday, November 17th. Bill Cooper, Jason Knox, Marcos Rodríguez-Ema, Arturo J. García-Solá, Isis Carballo-Irigoyen, Xenia Vélez, Samuel T. Céspedes Jr., Rubén Méndez-Benabe, Antonio J. Ramírez-Aponte and Sila M. González-Calderón, McConnell Valdés LLC, November 14, 2017. Now Tracking… Two Complex Bills – As expected, the Senate Finance Committee released its initial tax reform proposal on Friday. Separately, the House Ways and Means Committee put out its final legislative markup (the night before). Yes, we now have two bills to evaluate. Thankfully, you will see many overlapping provisions. On the other hand, expect challenges following the legislation, as each chamber of congress is introducing its own unique game-changers, and both bills add a ton of new complexity for multinationals. Albert Liguori and Kenneth Brewer, Alvarez & Marsal Holdings, LLC, November 13, 2017. House and Senate Plans Differ on Pass-Through Tax Rates – The 'Unified Framework' for tax reform of the Trump Administration and Congressional Republicans called for a 25 percent tax rate on pass-through business income, with appropriate safeguards to prevent the conversion of salaries and other personal services income into purported 'business' income. Two very different approaches to that objective are taken by the House bill approved in committee on Nov. 9, 2017, and the Senate Republican plan announced the same day. The approaches are so different that it is possible that entirely new ideas may surface to reconcile the differences. Here is an overview of the two approaches, and what may happen next. Don Susswein, RSM US LLP, November 13, 2017. The Tax Cuts and Jobs Act, Take Two: A Methods-Based Comparison of the Senate and House’s Tax Reform Plans – On November 9, 2017, the Senate Finance Committee (SFC) released a summary of its initial draft tax proposal (the Senate proposal). While the Senate proposal is similar to the House Ways and Means Committee’s proposal (the House proposal) (i.e., reduction in corporate tax rate, repeal of section 199 deduction, full expensing of certain business assets), many of the SFC’s proposed changes regarding deductions and credits are more nuanced than those in the House proposal. Ellen McElroy and Daniel G. Strickland, Eversheds Sutherland (US) LLP, November 13, 2017. Senate Tax Proposal Includes Comprehensive Business Tax Reform Measures – The Senate Finance Committee Chairman’s Mark of the Tax Cuts and Jobs Act includes substantial proposed changes to the corporate and international business taxation rules. While this proposal will evolve further in committee mark-up and beyond, taxpayers should be aware of several noteworthy provisions and key differences from the House bill. David G. Noren, Alexander Lee, Sandra P. McGill and Timothy S. Shuman, McDermott Will & Emery LLP, November 12, 2017. Chairman Brady Amends Key Parts of House Tax Bill – On Nov. 9, Chairman Brady of the House Ways and Means Committee proposed a second amendment (the “Amendment”) to the House tax reform bill. The Amendment modifies key provisions of the House Tax Reform Bill (H.R. 1), including the proposals that would lower the tax rate on pass-through business income, limit base erosion from cross border transactions, and the rules that would limit the dividends received deduction for corporations. The Joint Committee on Taxation estimates that the revised House bill will cost $1,436.9 billion. Rob Alinsky, RSM US LLP, November 10, 2017. The Senate Committee on Finance Releases Its Tax Reform Proposal – Senate Committee Proposes Sweeping Changes to U.S. Tax System – On Nov. 9th, the Senate Committee on Finance unveiled its own tax reform proposal, the “Tax Cuts and Jobs Act” following the recent release of the House proposal with the same name. While the actual legislative text has yet to be released, the Committee announced the bill’s main features in a policy highlight summary and the Joint Committee on Taxation released a description of the “Chairman’s Mark” of the bill. Ramon Camacho and Rob Alinsky, RSM US LLP, November 10, 2017. Finance Republicans Chart Their Own Course for Tax Reform – Senate Finance Committee Chairman Orrin Hatch, R-Utah, on November 9 released his version of a comprehensive tax reform proposal aimed at reducing rates and providing other tax relief for corporations, individuals, and passthrough entities that would be paid for in large part by eliminating or paring back dozens of current-law deductions, credits, and incentives. Deloitte Tax LLP, November 10, 2017. Tax Cuts and Jobs Act of 2017: A Weekly Update and Summary of Provisions Applicable to Small Businesses – The Tax Cuts and Jobs Act of 2017 has been hotly debated and analyzed since the Legislation was introduced by U.S. House Ways and Means Committee Chairman Kevin Brady (R-TX). On November 9, 2017, the Legislation was voted out of the Ways and Means Committee on a party-line vote. The debate on the Legislation is expected to continue next week to set up for a full House vote before the Thanksgiving recess. Steve Austria, Debora D. McGraw, Thomas R. Fagan and Adam L. Garn, Zaino Hall & Farrin LLC, November 10, 2017. Finance Committee Chairman Hatch Releases Senate Tax Reform Bill – Senate Finance Committee Chairman Orrin Hatch (R-UT) on November 9, 2017 released a Senate version of the ‘Tax Cuts and Jobs Act.’ The Senate tax reform proposals would lower business and individual tax rates, modernize US international tax rules, and simplify the tax law, but differ in key aspects from the House Ways and Means Committee-approved tax reform bill (HR 1). Pam Olson, Rohit Kumar, Scott McCandless, Todd Metcalf, Larry Campbell, Don Carlson, Janice Mays, Andrew Prior, Drew Lyon, Peter Merrill and Jon Lieber, PricewaterhouseCoopers LLP, November 10, 2017. Senate Releases Tax Reform Bill – On Thursday, November 9, 2017, the Senate Finance Committee released its version of tax reform legislation. The Senate bill, which comes one week after the House bill, departs from the House bill in several key areas. William M. Backstrom, Jr. and R. Christian Johnsen, Jones Walker LLP, November 10, 2017. Sometimes Smaller is Better – How H.R. 1 Offers Small Businesses Welcome Flexibility – Through the sea of commentary generated by the provisions in the Tax Cuts and Jobs Act (H.R. 1 or the Act) and its 429 pages of legislative text, there may be a gold lining for small businesses. Eversheds Sutherland (US) LLP, November 9, 2017. Ways and Means Chairman Brady Releases Tax Reform Discussion Draft – On November 2, 2017, House Ways and Means Chairman Kevin Brady (R-TX) released a 429-page ‘Chairman’s Mark’ to HR 1, the ‘Tax Cuts and Jobs Act’ (the Brady bill or the bill). If enacted, the bill would represent the largest overhaul of the US tax code (the Code) since the Tax Reform Act of 1986. Mike Urse, Michael DiFronzo, Tim Anson, Marty Collins, Charlie Markham, David Shapiro, David Sotos, Rebecca Lee, Oren Penn, Carl Dubert, Jeffrey Maddrey, Quyen Huynh, Matthew Chen, Stephen Nauheim, Jeffrey Dorfman, Elizabeth Nelson, Ethan Atticks, Ilene Fine and Jared Hermann, PricewaterhouseCoopers LLP, November 9, 2017.

On November 22, COST submitted written comments to California Franchise Tax Board (FTB) regarding a 2018 legislative proposal that would conform California to certain provisions from the 2015 Bipartisan Budget Act, which change the federal partnership audit procedures for tax years beginning on or after January 1, 2018.