The SALT Show with Baker Botts L.L.P.
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

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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

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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?

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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

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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

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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)

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).

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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?

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

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

September 26, 2019

The SALT Show Episode 77
(Update for Week of September 22, 2019)

On this week’s episode:

• Dividends received deduction litigation in Montana and Wisconsin
Connecticut digital goods sales tax legislation
California False Claims Act: Staving off the Sharks
Illinois passes mobile workforce safe harbor

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Linchpins and Business v. Nonbusiness Income

Linchpins and Business v. Nonbusiness Income

September 17, 2019

The SALT Show Episode 76
(Update for Week of September 15, 2019)

On this week’s episode:

• A primer on multistate taxation of business and nonbusiness income

Links to share the podcast with colleagues:
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We Don’t Need No Stinkin’ Legislation to Tax Marketplace Facilitators: Amazon and Walmart Case Updates

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

September 11, 2019

The SALT Show Episode 75
(Update for Week of September 9, 2019)

On this week’s episode:

An overview of the South Carolina Administrative Court in Amazon Services LLC v. Department of Revenue

A status update on Normand v. Wal-Mart.com USA LLC

Links to share the podcast with colleagues:
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