Ohio Supreme Court Waves Red Flag On Commercial Activity Tax Assessment

On Nov. 22, 2022, the Supreme Court of Ohio issued a much-anticipated opinion addressing the sourcing of gross receipts from transactions involving intangible property. In NASCAR Holdings, Inc. v. McClain, 2022-Ohio-4131, the court held that broadcast revenue, media revenue, licensing fees and sponsorship fees that NASCAR generates are not subject to the Ohio commercial activity tax (CAT). The court unanimously rejected an assessment as to CAT assessed for broadcast revenue, media revenue and sponsorship fees. […]

By | Jul 23, 2024 ||

NRA Withholdings—No Guns, Just Taxes

The term “NRA withholding” is not a reference to deductions from a person’s paycheck to support the National Rifle Association. Instead, it is a general term that refers to federal tax withholdings on payments of U.S.-sourced income to foreign persons under Sections 1441 to 1443 of the Internal Revenue Code. Foreign persons should be mindful of their tax filing and payment obligations under this regime.
NRA Withholding, Generally
As a general matter, a foreign person is […]

By | Jul 21, 2024 ||

Massachusetts State And Local Tax Update—Third Quarter 2022

The Massachusetts Appellate Tax Board remains closed to the public but is expected to resume in-person hearings later this year. In the meantime, there was no activity this quarter from the board, appellate courts, or commissioner of revenue with respect to state-level taxes. But there were several local property tax decisions addressing, among other things, exemption eligibility for solar power facilities, disregarded entities, and outdoor advertising structures.

In PelleVerde Capital, LLC v. Board of Assessors of […]

By | Jul 19, 2024 ||