The SALT Show with Baker Botts L.L.P.
MTC Whitepaper: Wayfair Implementation/Marketplace Facilitators

MTC Whitepaper: Wayfair Implementation/Marketplace Facilitators

December 5, 2019

The SALT Show Episode 87

(Update for Week of December 1, 2019)

 On this week’s episode:

  • An overview of the MTC's December 2, 2019 whitepaper on Wayfair implementation and marketplace facilitators.
  • Link to MTC Whitepaper

Send feedback and mailbag questions to: matt.hunsaker@bakerbotts.com

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

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

November 27, 2019

The SALT Show Episode 86

(Update for Week of November 24, 2019)

 On this week’s episode:

  • A brief update on state litigation against the feds over the $10,000 state and local tax deduction cap

Send feedback and mailbag questions to: matt.hunsaker@bakerbotts.com

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

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

November 21, 2019

The SALT Show Episode 85

(Update for Week of November 17, 2019)

On this week’s episode:

  • Preview of Wayfair & marketplace facilitator legislative “fixes”
  • Illinois has a constitutional problem?
  • Banks fight back on Washington’s B&O tax surcharge
  • California treatment of disregarded partnerships

 Send feedback and mailbag questions to: matt.hunsaker@bakerbotts.com

State Tax Lawyers are International Tax Lawyers

State Tax Lawyers are International Tax Lawyers

November 14, 2019

The SALT Show Episode 84
(Update for Week of November 10, 2019)

On this week’s episode:
Thoughts on revamping the show format
Don’t overlook SALT on cross-border transactions

Links to share the podcast with colleagues:
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Send feedback and mailbag questions to: matt.hunsaker@bakerbotts.com

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

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

November 5, 2019

The SALT Show Episode 83
(Update for Week of November 3, 2019)

On this week’s episode:
• Listener Contest: Economic nexus guess
• California’s latest on alternative apportionment regs
• Look-through sourcing: Microsoft’s Wisconsin case
• Alternative apportionment attack on royalty companies (Staples)
• Uber strikes back on local taxes

Links to share the podcast with colleagues:
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Send economic presence guesses and mailbag questions to matt.hunsaker@bakerbotts.com

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

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

October 30, 2019

The SALT Show Episode 82
(Update for Week of October 27, 2019)

On this week’s episode:
• Reflections on the COST 50th Annual Meeting
• Update on MTC’s working group to update PL 86-272 guidance for internet contacts
• Mailbag Question: How do you combine taxpayers with different apportionment formulas?

Links to share the podcast with colleagues:
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Send mailbag questions to matt.hunsaker@bakerbotts.com

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

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

October 23, 2019

The SALT Show Episode 81
(Update for Week of October 20, 2019)

On this week’s episode:
• Missouri’s 10-Year Refund Period
• New Hampshire adopts market-based sourcing
• Pennsylvania adopts an income tax nexus threshold
• Wisconsin provides a brightline test for nexus based on employee presence
Labell v. City of Chicago – Chicago streaming tax upheld

Links to share the podcast with colleagues:
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Send mailbag questions to matt.hunsaker@bakerbotts.com

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

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

October 16, 2019

The SALT Show Episode 80
(Update for Week of October 13, 2019)

On this week’s episode:
• How to argue constitutional issues before administrative bodies
Louisiana constitutional amendment to allows Board of Tax Appeals to hear constitutional issues
Louisiana issues guidance treating GILTI as dividends
Florida queues up Wayfair and marketplace facilitator legislation
• Preview of COST 50th Annual Meeting

Links to share the podcast with colleagues:
bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

Send mailbag questions to:matt.hunsaker@bakerbotts.com with the subject line "SALT Show Mailbag"

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)

October 11, 2019

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:
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Questions, comments, requests?
Email Matt Hunsaker at matt.hunsaker@bakerbotts.com

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

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

October 2, 2019

The SALT Show Episode 78
(Update for Week of September 29, 2019)

On this week’s episode:
• U.S. District Court dismisses states’ claims that $10,000 SALT deduction cap is unconstitutional
• An overview of the Utah Steiner case and implications for the external consistency test of apportionment
• Kansas Attorney General strikes down Kansas Department of Revenue Wayfair notice
• California sourcing of asset management services remains in limbo
• A California Supreme Court showdown on ballot initiative taxes?

Links to share the podcast with colleagues:
bakerbotts.com, iTunes, Stitcher, GooglePlay, Podbean, Spotify

Questions, comments, requests?
Email Matt Hunsaker at matt.hunsaker@bakerbotts.com