State Tax Matters

July 11th, 2025

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• Multistate Tax Alerts
  
  • California shifts to SSF apportionment for financial institutions and extends elective PTET
  • Louisiana enacts new filing methodology for S corporations
  • Texas enacts changes to research and development tax credit
• Amnesty:
  • New Hampshire – New Law Includes Tax Amnesty Program with Potential Waiver of Penalties and Reduced Interest

• Income/Franchise:
  
  • California – Budget Trailer Bill Implements Single Sales Factor Apportionment for Financial Institutions and PTET Extension
  • Connecticut – New Law Extends Corporation Business Tax Surcharge and Revises Certain NOL and Combined Reporting Provisions
  • Connecticut – New Law Creates Credit for Residents Related to “Convenience of the Employer” Rules Adopted by Other Jurisdictions
  • Florida – New Law Generally Updates State Conformity to Internal Revenue Code
  • Illinois – Bulletin Summarizes Recent Enactment of Finnigan Apportionment, Removal of Some Intercompany Expense Addback Exceptions, §163(j) Changes, and GILTI Taxation Changes
  • Indiana DOR Says Taxpayer May Claim Three Classes of Dividends Including Some Related to GILTI and FDII
  • Indiana DOR Abates Late Filing and Underpayment Penalties Due in Part to Combined Filer’s Complex Returns and Filing History
  • Maine – New Law Updates State Conformity to Internal Revenue Code
  • Maine Revenue Services Adopts Revised Rule that Seeks to Clarify Sourcing Receipts from Services
  • Massachusetts Supreme Court Denies Review of Case Affirming that Individual’s Stock Sale in Company is Taxable Despite Subsequent Nonresidence
  • Tennessee – Updated Franchise and Excise Tax Manual Clarifies Filing Periods in F Reorganizations
  • Texas – Company’s Costs for Acquiring Virtual Currency Deemed Ineligible for COGS and Sales of These Assets are Sourced to Location of Payor
• Gross Receipts:
  • Ohio – Enacted Budget Bill Turns CAT Credits for Certain Accrued NOLs from Refundable to Nonrefundable
  • Tennessee – Updated Business Tax Manual Includes Working Example on Whether Remote Sellers Have Nexus
• Sales/Use/Indirect:
  • Colorado Appellate Court Reverses Lower Court to Hold that Online Streaming Subscriptions Constitute Taxable TPP
  • Florida – New Law Repeals Business Rent Tax as of October 1, 2025
  • Illinois – Adopted Rule Changes Reflect New Destination-Based Sourcing for Some Retailers
  • Kentucky Department of Revenue Addresses Taxability of Tariffs in Response to Increased Inquiries
  • Louisiana – New Law Defines Drop Shipment Sales and Provides Special Situsing Rules for These Sales
  • Maryland Comptroller Explains New 3% Sales Tax on Certain Information Technology and Data Services and MPU Provisions
  • Ohio – Enacted Budget Bill Repeals Some Exemptions, Eliminates Interest on Some Refunds, and Caps Prompt Payment Vendor Discount
  • Tennessee – Updated Tax Manual Includes Guidance and Examples on Taxability of Tariffs
• Property:
  • Arizona – New Law Increases Personal Property Tax Exemption for Certain Business Properties
• Unclaimed Property:
  • Delaware – Reminder: Voluntary Disclosure Agreement Invitation Response Deadline is Approaching
  • Oregon – New Law Defines and Addresses Treatment and Liquidation of Abandoned Digital Assets

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