v. Idaho State Tax Commission, 470 P.3d 1176 (Idaho 2020). In its decision, the Idaho Supreme Court held that Idaho could not tax a holding company on any portion of its gain from the sale of a multistate business that had operated in that state for almost two decades. In its amicus brief, the Commission pointed out that the U.S. Supreme Court has never considered the application of the unitary business principle to a business enterprise that includes a holding company, resulting in a gap in Due Process Clause jurisprudence, and that the Idaho Supreme Court’s decision contributes to a growing conflict among state courts and administrative tribunals.
The Statement was last revised in 2001. In this article, Brian Hamer, MTC counsel, describes the proposed revisions to the Statement and the path that the work group pursued to reach the decisions they made.
Georgetown Law and the Multistate Tax Commission (“MTC”) have partnered to provide a 20% tuition discount to state and local tax government attorneys and qualified non-attorney tax professionals who matriculate in the 2021-2022 LL.M., MSL, or SALT Certificate Distance Learning programs.
Georgetown Law and the Multistate Tax Commission (“MTC”) have partnered to provide a 20 percent tuition discount to state and local tax government attorneys and qualified non-attorney tax professionals who matriculate in the 2021-2022 LL.M., MSL, or SALT Certificate Distance Learning programs.
Iowa Department of Revenue and Finance in light of the federal tax changes popularly referred to as the Tax Cuts and Jobs Act (“TCJA”). The TCJA extended the definition of federal taxable income to so-called “deemed repatriation income” and global intangible low-taxed income or “GILTI.” Some have claimed that Kraft restricts the states with respect to taxing this income. Fatale’s article posits that these readings of Kraft are incorrect, that Kraft was incorrectly decided, and that it is overdue for judicial reconsideration as Quill was in Wayfair.