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 24-25; December 13, 2024

Preparing for an Active 2025 – The softening of state revenues and the plethora of bills already prefiled for the 2025 session in many states indicate that 2025 will be a very active year for SALT legislation. Although 2024 was relatively quiet, there was some notable state legislation introduced that is likely to resurface in 2025. Which of the following would have the greatest negative impact on

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Bloomberg TAX

Pharma Exec Fights $3 Million Micro-captive Assessment from IRS

January 17, 2025

A former Massachusetts business owner is fighting IRS denials of tax credits related to his company's micro-captive insurance.

Los Angeles Mansion Tax Violates City’s Charter, Opponents Argue

January 17, 2025

A Los Angeles tax on property sales of over $5 million is invalid because the city's charter prohibits transfer taxes earmarked for special purposes, challengers told a California appeals court.

IRS PLR: Conditional Approval Granted for 5-Year Automatic Extension for Amortization Periods of Unfunded Liabilities of Plan (IRC §431)

January 17, 2025

The IRS has published a private letter ruling on Section 431, regarding an extension of the amortization periods of the unfunded liabilities of a plan. [PLR 202502007]

Yellen Says US to Take Extraordinary Steps to Avert Default (1)

January 17, 2025

Outgoing Treasury Secretary Janet Yellen said her department will start taking special accounting maneuvers as of Jan. 21 to avoid breaching the US debt limit, and urged lawmakers again to take steps to increase or suspend the statutory ceiling.

Virginia Man Pleads Guilty to Real Estate Fraud, Tax Crimes

January 17, 2025

A Virginia man pleaded guilty to real estate and tax fraud related to his scheme to obtain title to a $1.3 million home in Roanoke County, the Justice Department announced Friday.

IRS’s Crypto Rule for Brokers Teed Up for Senate GOP Repeal

January 17, 2025

Sen. Ted Cruz is introducing a measure aimed at overturning the IRS's rule requiring certain cryptocurrency brokers to report details of sales and exchanges, giving Republicans the ability to overturn the Biden-era regulation in the coming weeks.

ScottishPower Can Deduct Regulatory Deal Payments, UK Court Says

January 17, 2025

A UK court cleared a power company’s multimillion-pound tax deduction for payments stemming from a regulatory settlement, rebuffing His Majesty’s Revenue & Customs' attempt to block the tax break.

State of Tax: Cuts for NY, Digital Ad Tax Plan for Rhode Island

January 17, 2025

The week in state tax news: As legislative and budget seasons begin, governors are laying out revenue and tax-relief agendas. New York's governor proposed an income tax cut plus a number of credits, while in Rhode Island there was a digital advertising tax proposal. In Congress, the SALT cap repeal effort took legislative form.

IRS Loses Bid to Trim Basis Price of Conservation Easement Land

January 17, 2025

The IRS failed a bid to trim the basis price for a parcel of land at the heart of a disputed conservation easement donation.

Case: No Causal Link Between Identity Theft and Delay in Filing Petition; Motion to Dismiss Granted (T.C. Memo) (IRC §6330)

January 17, 2025

The Tax Court lacked jurisdiction to review the IRS's determination to sustain a notice of intent to levy due to the taxpayers' untimely petition, which was not subject to equitable tolling, held the U.S. Tax Court, granting the IRS's motion to dismiss. Taxpayers, a married couple, had an unpaid federal income tax liability for 2015. The IRS levied on their state tax refund and issued a notice of determination sustaining the levy after a CDP hearing. Taxpayers filed a petition with the Tax Court over four years after the 30-day deadline specified in I.R.C. §6330(d)(1). The Tax Court held that it lacked jurisdiction because the petition was untimely and the taxpayers failed to establish grounds for equitable tolling. Although the taxpayers claimed they were victims of identity theft, this occurred years before the notice of determination was issued and did not explain the four-year delay in filing the petition. The court found no causal link between the identity theft and the untimely petition, noting that different facts could potentially establish equitable tolling based on identity theft, but such facts were not present in this case. Accordingly, the court granted the IRS's motion to dismiss for failure to state a claim upon which relief could be granted. [Reed v. Commissioner, T.C. Memo 2025-4 (Jan. 16, 2025)]

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

Comments In Opposition to the MRS Proposed Amendments to Rule 801 and Hearing Request

COST submitted comments to the Maine Revenue Services in opposition to proposed amendments to Rule 801 (Apportionment) specifically that some of the language of the proposed amendments represents an expansion of Maine Revenue Services’ authority that is not supported by any statutory change and that any change in administrative policy that negatively impacts taxpayers should apply prospectively on