A Taxing Day at the Texas Supreme Court: Sunstate, AMC, and Gulf Copper; California OTA Shuts Down FTB’s Treatment of Out-of-State LLC Members (Jali)

Update: 2019-10-11

Description

The SALT Show Episode 79

(Update for Week of October 6, 2019)

On this week’s episode:

• An overview of Texas Supreme Court oral arguments in several Texas franchise tax “cost of goods sold” cases, including Sunstate Rentals, American Multi-Cinema, and Gulf Copper

• The California Office of Tax Appeals shuts down the Franchise Tax Board’s 0.2% bright line test for taxing out-of-state members of LLCs doing business in California (Appeal of Jali).

Links to share the podcast with colleagues:

bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

Comments

In Channel

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State Tax Legislative Update

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Keeping Communications with Tax Accountants and Consultants Confidential

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ALJ Roundup: Hedging Transactions & Unitary Income (Texas) & Alt Apportionment & Royalty Exclusion (New York)

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All the Income Tax Stuff You Missed Over Thanksgiving

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MTC Whitepaper: Wayfair Implementation/Marketplace Facilitators

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Update on States' Suit Against Feds over $10K SALT Deduction Cap

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Unconstitutional Wayfair/Marketplace Rules; Banks Take on the Washington B&O Tax Surcharge; California & Disregarded Partnerships

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Tidbits on Alternative Apportionment (FTB Regs, Staples); Look-Through Sourcing Shot Down (Microsoft); Ride Sharing Takes on Local Taxes

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COST Annual Meeting; Combination & Industry Apportionment; PL 86-272 Update

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Wayfair & Income Tax Nexus; Market-Based Sourcing, & Local Taxes

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Arguing Constitutional Issues at Administrative Courts, Louisiana GILTI Guidance, & Florida Joining the Wayfair Club

2019-10-1606:41

A Taxing Day at the Texas Supreme Court: Sunstate, AMC, and Gulf Copper; California OTA Shuts Down FTB’s Treatment of Out-of-State LLC Members (Jali)

2019-10-1112:41

Death of External Consistency? (Steiner), California Sourcing of Asset Management Services, Showdown on California Local Taxes, Kansas Remote Seller Policy Struck Down

2019-10-0208:34

Dividends Received Deduction Litigation, Digital Goods, California False Claims Act, and Illinois Mobile Workforce Safe Harbor

2019-09-2607:37

Linchpins and Business v. Nonbusiness Income

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We Don’t Need No Stinkin’ Legislation to Tax Marketplace Facilitators: Amazon and Walmart Case Updates

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A Taxing Day at the Texas Supreme Court: Sunstate, AMC, and Gulf Copper; California OTA Shuts Down FTB’s Treatment of Out-of-State LLC Members (Jali)

#box-pro-ellipsis-176056406049872{-webkit-line-clamp:2;}A Taxing Day at the Texas Supreme Court: Sunstate, AMC, and Gulf Copper; California OTA Shuts Down FTB’s Treatment of Out-of-State LLC Members (Jali)

A Taxing Day at the Texas Supreme Court: Sunstate, AMC, and Gulf Copper; California OTA Shuts Down FTB’s Treatment of Out-of-State LLC Members (Jali)

Baker Botts L.L.P.

A Taxing Day at the Texas Supreme Court: Sunstate, AMC, and Gulf Copper; California OTA Shuts Down FTB’s Treatment of Out-of-State LLC Members (Jali)