Key questions legislators should ask when evaluating tax incentives:
â˘What is the problem we are trying to solve?
â˘What will we create with this incentive?
â˘Does this incentive create a competitive advantage?
â˘How will we measure the impact?
â˘Who is in charge of collecting data and reporting it?
â˘How does this incentive fit into the larger mix?
â˘If we had to appropriate budget dollars for this incentive package, would we spend it?
â˘How much is too much?
Franklin County Entrepreneur Express #3 Presentation, May 12, 2010Sandy Ratliff
Â
The Virginia Department of Business Assistance partnered with the Franklin County Chamber of Commerce, West Piedmont Business Development Center, the Franklin Center and Longwood Small Business Development Center to conduct a workshop focused on steps to starting and growing a business in Virginia.
State and Local Tax Nexus Issues and the Impact on Mergers and AcquisitionsSkoda Minotti
Â
Would you sell a home before making it attractive enough to turn a profit? Selling a business is no different. Before you plan to sell, there are essential tax implications you should understand and steps you should take to ensure smooth sailing for a successful transaction
The Importance of State and Local Tax NexusSkoda Minotti
Â
This course will lay out some of the important aspects of state income tax and sales tax nexus concerns, then address the importance of performing detailed state and local tax due diligence. It will also discuss the importance of performing due diligence to address the potential sins of the past before actually entering the M&A market.
Key questions legislators should ask when evaluating tax incentives:
â˘What is the problem we are trying to solve?
â˘What will we create with this incentive?
â˘Does this incentive create a competitive advantage?
â˘How will we measure the impact?
â˘Who is in charge of collecting data and reporting it?
â˘How does this incentive fit into the larger mix?
â˘If we had to appropriate budget dollars for this incentive package, would we spend it?
â˘How much is too much?
Franklin County Entrepreneur Express #3 Presentation, May 12, 2010Sandy Ratliff
Â
The Virginia Department of Business Assistance partnered with the Franklin County Chamber of Commerce, West Piedmont Business Development Center, the Franklin Center and Longwood Small Business Development Center to conduct a workshop focused on steps to starting and growing a business in Virginia.
State and Local Tax Nexus Issues and the Impact on Mergers and AcquisitionsSkoda Minotti
Â
Would you sell a home before making it attractive enough to turn a profit? Selling a business is no different. Before you plan to sell, there are essential tax implications you should understand and steps you should take to ensure smooth sailing for a successful transaction
The Importance of State and Local Tax NexusSkoda Minotti
Â
This course will lay out some of the important aspects of state income tax and sales tax nexus concerns, then address the importance of performing detailed state and local tax due diligence. It will also discuss the importance of performing due diligence to address the potential sins of the past before actually entering the M&A market.
Smith Haughey Rice & Roegge presents the latest in property taxes for 2014. Smithhaughey
Â
A seminar that walks you through taxes 101, personal property taxes, exempt property, recent developments in real property taxation, real estate tax issues for seniors and veterans, planning opportunities and pitfalls.
Overview of the services provided by the San Diego Center for International Trade Development including no-cost one-on-one counseling for export regulations, international market research, finding overseas markets, and more. By Victor Castillo - San Diego Center for International Trade Development.
Everything your startup needs to know about accountingThe Idea Village
Â
Don't get lost in the accounting world as you steer your venture to success! In this IDEAinstitute, attendees will be guided by the accounting startup compass: tools and insights of the trade necessary to reach your venture's destination.
Legalshield Business Solutions (Formerly Pre Paid Legal)Daedalus294
Â
Legalshield offers a suite of services designed to give you piece of mind. Whether you are a small business, HR manager, or an insurance broker / agent, we provide solutions for everyone.
Affordable legal protection and comprehensive identity theft protection with a *5 million dollar guarantee.
Get Legalshield for your business to cover your employees. Benefits include: no additional cost to employer, no underwriting, boosting the bottom line, and keeping employees focused on their jobs instead of their personal problems.
We offer generous commissions and bonuses to those that qualify. We are in a high growth market with virtually no competition. We protect more than 1.5 million people across the US and Canada.
Best residual income rates and we pay well. Bonuses and reward trips for those who who can qualify every quarter.
We make it one best business opportunity.
For more information: https://business.legalshield.com/?hub=kamilfaizi
Slack (or Teams) Automation for Bonterra Impact Management (fka Social Soluti...Jeffrey Haguewood
Â
Sidekick Solutions uses Bonterra Impact Management (fka Social Solutions Apricot) and automation solutions to integrate data for business workflows.
We believe integration and automation are essential to user experience and the promise of efficient work through technology. Automation is the critical ingredient to realizing that full vision. We develop integration products and services for Bonterra Case Management software to support the deployment of automations for a variety of use cases.
This video focuses on the notifications, alerts, and approval requests using Slack for Bonterra Impact Management. The solutions covered in this webinar can also be deployed for Microsoft Teams.
Interested in deploying notification automations for Bonterra Impact Management? Contact us at sales@sidekicksolutionsllc.com to discuss next steps.
Smith Haughey Rice & Roegge presents the latest in property taxes for 2014. Smithhaughey
Â
A seminar that walks you through taxes 101, personal property taxes, exempt property, recent developments in real property taxation, real estate tax issues for seniors and veterans, planning opportunities and pitfalls.
Overview of the services provided by the San Diego Center for International Trade Development including no-cost one-on-one counseling for export regulations, international market research, finding overseas markets, and more. By Victor Castillo - San Diego Center for International Trade Development.
Everything your startup needs to know about accountingThe Idea Village
Â
Don't get lost in the accounting world as you steer your venture to success! In this IDEAinstitute, attendees will be guided by the accounting startup compass: tools and insights of the trade necessary to reach your venture's destination.
Legalshield Business Solutions (Formerly Pre Paid Legal)Daedalus294
Â
Legalshield offers a suite of services designed to give you piece of mind. Whether you are a small business, HR manager, or an insurance broker / agent, we provide solutions for everyone.
Affordable legal protection and comprehensive identity theft protection with a *5 million dollar guarantee.
Get Legalshield for your business to cover your employees. Benefits include: no additional cost to employer, no underwriting, boosting the bottom line, and keeping employees focused on their jobs instead of their personal problems.
We offer generous commissions and bonuses to those that qualify. We are in a high growth market with virtually no competition. We protect more than 1.5 million people across the US and Canada.
Best residual income rates and we pay well. Bonuses and reward trips for those who who can qualify every quarter.
We make it one best business opportunity.
For more information: https://business.legalshield.com/?hub=kamilfaizi
Slack (or Teams) Automation for Bonterra Impact Management (fka Social Soluti...Jeffrey Haguewood
Â
Sidekick Solutions uses Bonterra Impact Management (fka Social Solutions Apricot) and automation solutions to integrate data for business workflows.
We believe integration and automation are essential to user experience and the promise of efficient work through technology. Automation is the critical ingredient to realizing that full vision. We develop integration products and services for Bonterra Case Management software to support the deployment of automations for a variety of use cases.
This video focuses on the notifications, alerts, and approval requests using Slack for Bonterra Impact Management. The solutions covered in this webinar can also be deployed for Microsoft Teams.
Interested in deploying notification automations for Bonterra Impact Management? Contact us at sales@sidekicksolutionsllc.com to discuss next steps.
Accelerate your Kubernetes clusters with Varnish CachingThijs Feryn
Â
A presentation about the usage and availability of Varnish on Kubernetes. This talk explores the capabilities of Varnish caching and shows how to use the Varnish Helm chart to deploy it to Kubernetes.
This presentation was delivered at K8SUG Singapore. See https://feryn.eu/presentations/accelerate-your-kubernetes-clusters-with-varnish-caching-k8sug-singapore-28-2024 for more details.
GDG Cloud Southlake #33: Boule & Rebala: Effective AppSec in SDLC using Deplo...James Anderson
Â
Effective Application Security in Software Delivery lifecycle using Deployment Firewall and DBOM
The modern software delivery process (or the CI/CD process) includes many tools, distributed teams, open-source code, and cloud platforms. Constant focus on speed to release software to market, along with the traditional slow and manual security checks has caused gaps in continuous security as an important piece in the software supply chain. Today organizations feel more susceptible to external and internal cyber threats due to the vast attack surface in their applications supply chain and the lack of end-to-end governance and risk management.
The software team must secure its software delivery process to avoid vulnerability and security breaches. This needs to be achieved with existing tool chains and without extensive rework of the delivery processes. This talk will present strategies and techniques for providing visibility into the true risk of the existing vulnerabilities, preventing the introduction of security issues in the software, resolving vulnerabilities in production environments quickly, and capturing the deployment bill of materials (DBOM).
Speakers:
Bob Boule
Robert Boule is a technology enthusiast with PASSION for technology and making things work along with a knack for helping others understand how things work. He comes with around 20 years of solution engineering experience in application security, software continuous delivery, and SaaS platforms. He is known for his dynamic presentations in CI/CD and application security integrated in software delivery lifecycle.
Gopinath Rebala
Gopinath Rebala is the CTO of OpsMx, where he has overall responsibility for the machine learning and data processing architectures for Secure Software Delivery. Gopi also has a strong connection with our customers, leading design and architecture for strategic implementations. Gopi is a frequent speaker and well-known leader in continuous delivery and integrating security into software delivery.
Dev Dives: Train smarter, not harder â active learning and UiPath LLMs for do...UiPathCommunity
Â
đĽ Speed, accuracy, and scaling â discover the superpowers of GenAI in action with UiPath Document Understanding and Communications Miningâ˘:
See how to accelerate model training and optimize model performance with active learning
Learn about the latest enhancements to out-of-the-box document processing â with little to no training required
Get an exclusive demo of the new family of UiPath LLMs â GenAI models specialized for processing different types of documents and messages
This is a hands-on session specifically designed for automation developers and AI enthusiasts seeking to enhance their knowledge in leveraging the latest intelligent document processing capabilities offered by UiPath.
Speakers:
đ¨âđŤ Andras Palfi, Senior Product Manager, UiPath
đŠâđŤ Lenka Dulovicova, Product Program Manager, UiPath
Search and Society: Reimagining Information Access for Radical FuturesBhaskar Mitra
Â
The field of Information retrieval (IR) is currently undergoing a transformative shift, at least partly due to the emerging applications of generative AI to information access. In this talk, we will deliberate on the sociotechnical implications of generative AI for information access. We will argue that there is both a critical necessity and an exciting opportunity for the IR community to re-center our research agendas on societal needs while dismantling the artificial separation between the work on fairness, accountability, transparency, and ethics in IR and the rest of IR research. Instead of adopting a reactionary strategy of trying to mitigate potential social harms from emerging technologies, the community should aim to proactively set the research agenda for the kinds of systems we should build inspired by diverse explicitly stated sociotechnical imaginaries. The sociotechnical imaginaries that underpin the design and development of information access technologies needs to be explicitly articulated, and we need to develop theories of change in context of these diverse perspectives. Our guiding future imaginaries must be informed by other academic fields, such as democratic theory and critical theory, and should be co-developed with social science scholars, legal scholars, civil rights and social justice activists, and artists, among others.
UiPath Test Automation using UiPath Test Suite series, part 3DianaGray10
Â
Welcome to UiPath Test Automation using UiPath Test Suite series part 3. In this session, we will cover desktop automation along with UI automation.
Topics covered:
UI automation Introduction,
UI automation Sample
Desktop automation flow
Pradeep Chinnala, Senior Consultant Automation Developer @WonderBotz and UiPath MVP
Deepak Rai, Automation Practice Lead, Boundaryless Group and UiPath MVP
Connector Corner: Automate dynamic content and events by pushing a buttonDianaGray10
Â
Here is something new! In our next Connector Corner webinar, we will demonstrate how you can use a single workflow to:
Create a campaign using Mailchimp with merge tags/fields
Send an interactive Slack channel message (using buttons)
Have the message received by managers and peers along with a test email for review
But thereâs more:
In a second workflow supporting the same use case, youâll see:
Your campaign sent to target colleagues for approval
If the âApproveâ button is clicked, a Jira/Zendesk ticket is created for the marketing design team
Butâif the âRejectâ button is pushed, colleagues will be alerted via Slack message
Join us to learn more about this new, human-in-the-loop capability, brought to you by Integration Service connectors.
And...
Speakers:
Akshay Agnihotri, Product Manager
Charlie Greenberg, Host
DevOps and Testing slides at DASA ConnectKari Kakkonen
Â
My and Rik Marselis slides at 30.5.2024 DASA Connect conference. We discuss about what is testing, then what is agile testing and finally what is Testing in DevOps. Finally we had lovely workshop with the participants trying to find out different ways to think about quality and testing in different parts of the DevOps infinity loop.
The Art of the Pitch: WordPress Relationships and SalesLaura Byrne
Â
Clients donât know what they donât know. What web solutions are right for them? How does WordPress come into the picture? How do you make sure you understand scope and timeline? What do you do if sometime changes?
All these questions and more will be explored as we talk about matching clientsâ needs with what your agency offers without pulling teeth or pulling your hair out. Practical tips, and strategies for successful relationship building that leads to closing the deal.
2. 2013 Praxity International Tax Conference
Atlanta
AGENDA
⢠Introduction
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
3. 2013 Praxity International Tax Conference
Atlanta
Objectives
⢠Provide an overview of state and local taxation in the
United States
⢠Highlight important trends
⢠Explain planning opportunities and pitfalls
Introduction
4. 2013 Praxity International Tax Conference
Atlanta
⢠Corporate income tax â45 states
â Exceptions: NV, OH, SD, WA, and WY
⢠Personal income tax â43 states
â Exceptions: AK, FL, NH (int. & div.), NV, SD, TN (int. & div.), WA, TX, and WY
⢠Sales & use tax â45 states
â Exceptions: AK, DE, MT, NH, and OR
⢠Property tax â50 states
State and Local Taxes At AGlance
Introduction
5. 2013 Praxity International Tax Conference
Atlanta
AGENDA
⢠Introduction
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
6. 2013 Praxity International Tax Conference
Atlanta
State Tax Nexus
What is nexus?
⢠Nexus is defined as the connection between a taxpayer and a state that is
necessary before a state can impose taxes
Income tax nexus differs from sales tax nexus
⢠Income tax nexus: limited by Public Law 86â272
⢠Sales tax nexus: limited by âPhysical Presenceâ or the âQuillâ requirement
Nexus
7. 2013 Praxity International Tax Conference
Atlanta
Nexus For Income Tax: PL 86â272
Federal law prohibits states and cities from imposing a net income tax on
an outâofâstate company if the only connection to the state is the solicitation
of sales of tangible personal property
PL 86â272: General Rule
⢠Company must be selling Tangible Personal Property
⢠Sales of services or intangible property not protected
⢠Only activity in the state is solicitation of sales
⢠Order for good must be sent outside the state for approval
⢠Goods are shipped from outâofâstate
⢠Only applies to U.S. corporations, but some states honor foreign (nonâU.S.)
corporations
Nexus
8. 2013 Praxity International Tax Conference
Atlanta
Nexus For Sales Tax: Physical Presence
⢠States generally prohibited from imposing sales tax collection requirements on outâ
ofâstate vendors
⢠U.S. Supreme court has affirmed that a vendor must have physical presence to create
sales tax nexus (Quill Corp. v. North Dakota , 1992)
Examples of Physical Presence
⢠Deliveries in company owned vehicles or backhauling property
⢠Occasional visits by sales persons or other personnel
⢠Trade shows (limitations)
⢠Fulfillment centers and warehouses
⢠Servers and/or hosted websites
⢠Agents and affiliates performing services in the state on
your behalf
⢠Consigned inventory & vendor managed inventory
⢠Dealer training
⢠Warranty work
Nexus
9. 2013 Praxity International Tax Conference
Atlanta
Nexus Trends
Lawmakers are finding new ways to impose state taxes on outâofâstate
companies that lack traditional physical presence nexus
⢠Nexus through agency or affiliation
⢠An outâofâstate company may be taxable based on its relationship to an inâ
state company
⢠âAmazon Lawsâ and clickâthrough nexus
⢠Outâofâstate seller creates sales tax nexus with a state when it enters into
an agreement with a resident of that state, under which the resident
refers buyers via a website link for a commission.
⢠Adopted in AR, CA, CT, IL, MN, MO, NC, NY, OH, PA, RI, SC (2016), VT
⢠Many other states are considering
⢠Federal legislation
⢠Marketplace Fairness Act of 2013 (âInternet Sales Taxâ): Would allow states to
impose sales tax collection requirement on certain remote sellers
⢠As of this writing, the Act has passed the U.S. Senate and has moved to the
House of Representatives
Nexus
10. 2013 Praxity International Tax Conference
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Nexus Trends
Economic Nexus Scorecard
⢠Factor Presence Nexus
⢠CA (>$500,000 of receipts)
⢠CT (>$500,000 of receipts)
⢠CO (>$500,000 of receipts)
⢠MI (>$350,000 of receipts)
⢠OH (>$500,000 of receipts)
⢠WA (>$250,000 of receipts)
⢠Deriving receipts or income from inâ
state sources
⢠IA
⢠KY
⢠MN
⢠NJ
⢠OR
⢠WI
Nexus
⢠Economic nexus
⢠Income taxes imposed when a
specific dollar amount of sales,
property or payroll
⢠Some states have more vague
definitions
⢠Applies to income from services,
royalties, interest, digital goods
⢠P.L. 86â272 protects sales of
tangible personal property
11. 2013 Praxity International Tax Conference
Atlanta
AGENDA
⢠Objectives
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
12. 2013 Praxity International Tax Conference
Atlanta
Business Income/Franchise Tax
46 states plus The District of Columbia impose an income and/or franchise
tax
⢠Income taxes are imposed on corporations
â Rates generally range from 1% to 12%
⢠Franchise taxes are imposed on business entities
â Tax base is capital or net worth
â Rates generally range from $1.50â3.00 per $1,000 net worth
â More than half of the states impose some sort of franchise tax
Filing methods generally include combined, consolidated, and separate
Business Income Tax
13. 2013 Praxity International Tax Conference
Atlanta
Separate reporting
Each business entity with nexus is treated as a separate taxpayer
Combined reporting
⢠Businesses that are part of a âunitaryâ group file a combined tax return
⢠Characteristics of a âunitaryâ business:
â Contribution & dependency
â Strong centralized management
â Economies of scale/flow of goods
⢠Intercompany transactions are eliminated
⢠May include nonâU.S. affiliates owned > 50%
â A nonâUS affiliate is typically excluded if 80% or more of its business
activity is outside the U.S
⢠Trend: More states are requiring combined reporting in order to increase
their tax base
Separate vs. Combined Reporting
Business Income Tax
14. 2013 Praxity International Tax Conference
Atlanta
Federal Taxable Income Base
+/âState Modifications
= Apportionable State Income
x Apportionment Percentage
= State Taxable Income
x State Tax Rate
= State Tax Amount
State Taxable Income Formula
Business Income Tax
15. 2013 Praxity International Tax Conference
Atlanta
Federal income taxes
State income taxes
Depreciation
⢠Many states disallow Federal âbonusâ
depreciation
Expenses paid to related parties
⢠Includes interest, royalties, management
fees
⢠Trend: More states are disallowing relatedâ
party expenses to prevent taxpayers from
shifting income to lowâtax jurisdictions
Common Modifications
Business Income Tax
16. 2013 Praxity International Tax Conference
Atlanta
Apportionment: Basic Principles
What percentage of the companyâs income may the
state tax?
⢠Nonâuniformity: Rules vary from state to state
â May result in double taxation or ânowhere salesâ
Planning opportunity: Consider state apportionment
rules when locating or expanding your business
Business Income Tax
Total apportionable State Income
x Apportionment Percentage
= Apportioned Business Income
17. 2013 Praxity International Tax Conference
Atlanta
Apportionment Formulas
Traditional 3-Factor Apportionment Formula
Inâstate Sales
Total Sales
Inâstate Payroll
Total Payroll
Inâstate Property
Total Property
3
Trends in apportionment formulas:
⢠Shift towards single sales factor or multipleâweighted sales factor
⢠Decreases tax burden of companies with inâstate property and payroll
Business Income Tax
18. 2013 Praxity International Tax Conference
Atlanta
Apportionment âSales Factor
What is included and where is it sourced?
Tangible Personal Property:
⢠Sales sourced to destination state
⢠âThrowback ruleâ in some states: When the seller is not taxable in the
destination state, sales are sourced to the state shipped from
Services:
⢠Cost of performance method: Sales sourced to state in which
âincome producing activityâ is performed
⢠Market sourcing method: Sales sourced to state in which customer
receives the benefit of the service
⢠Favors inâstate service providers who have outâofâstate sales.
⢠Trend: More states are moving to a marketâbased rule
⢠Current market states: AL, CA, GA, IL, MD, MI, MN, NE (eff.
2014), OH, WA, & WI
Business Income Tax
19. 2013 Praxity International Tax Conference
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Residents are taxed on their worldwide
income (including investment income that is
sourced to state of residence). To prevent
doubleâtaxation, may claim credit for taxes
paid to other states
Nonresidents are taxed on their stateâsource
income (wages and apportioned business
income)
Tax rates range from 3.4% â 12.3%
Personal Income Tax
Personal Income Tax
20. 2013 Praxity International Tax Conference
Atlanta
AGENDA
⢠Objectives
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
21. 2013 Praxity International Tax Conference
Atlanta
State Sales & Use Tax
45 states plus The District of Columbia impose a general Sales & Use Tax
⢠Five states do not: Alaska, Delaware, Montana, New Hampshire and Oregon
Average rates range from 4â10%
Tax is imposed on buyer, but seller is required to collect it
Home Rule vs. Nonâhome Rule
Nonâhome rule (general rule)
⢠Usually, states administer and collect all state, city and other local sales taxes
Home rule:
⢠Certain local governments are authorized to impose and collect their own
sales tax
⢠Watch out for local filing requirements in: Alabama, Alaska (local only), Arizona,
Colorado, Illinois and Louisiana
Sales & Use Tax
22. 2013 Praxity International Tax Conference
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What is taxable?
In general, all sales of tangible personal property are subject to sales tax
⢠Exemptions may apply (varies by state)
Other transactions/products may also be subject to sales tax (varies by state):
⢠Services (42 states), intangibles, computer software, utilities
Common exemptions from sales tax include:
⢠Sale for resale
⢠Examples: Food by a restaurant, raw materials by a manufacturer
⢠Seller must obtain resale certificate
⢠Casual or Occasional Sales
⢠Component parts of manufacturing products
⢠Sales of machinery or equipment
⢠Essential items (food and medical devices)
Sales Tax âExemptions From Base
Sales & Use Tax
23. 2013 Praxity International Tax Conference
Atlanta
AGENDA
⢠Objectives
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
24. 2013 Praxity International Tax Conference
Atlanta
Primary source of revenue for
local governments
Rates generally range from 1â5%
Tax Base
⢠Based on FMV, not cost
⢠Assessed value on specified date (e.g., lien date)
Taxable Property
⢠All forms of realty: land, personal residences, apartment
buildings, offices, factories, etc.
⢠Selected types of tangible personal property (varies by state)
⢠Inventory is generally exempt
⢠States to watch out for: AK, AR, KY, LA, MA, OK, TX, VA, VT, WV
Property Taxes
Property Taxes
25. 2013 Praxity International Tax Conference
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AGENDA
⢠Objectives
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
26. 2013 Praxity International Tax Conference
Atlanta
Credits and Incentives
States provide a variety of credits and incentives to attract businesses to their jurisdiction
Credits and incentives are commonly provided for:
⢠Creating jobs (especially for disadvantaged employees)
⢠Investment / targeted economic development in high unemployment areas
⢠Research & development
⢠Targeted sectors (e.g., energy, agriculture, manufacturing, and healthcare)
Many states also offer cash grants for certain business activities
⢠Employment, training and education
⢠Large or very targeted expansions
Many incentives are negotiable, and must be done in advance of investment
Some incentives are statutory and many be claimed if activity done by eligible company
Certain credits are transferable (may be sold to another business)
Credits & Incentives
27. 2013 Praxity International Tax Conference
Atlanta
AGENDA
⢠Objectives
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
28. 2013 Praxity International Tax Conference
Atlanta
⢠If your client already has business activity in the United States,
they probably have filing obligations that they do not know about
⢠Income tax:
⢠Treaties between the U.S. and foreign governments may not
protect a nonâU.S. company from state taxation
⢠A nonâU.S. company may have nexus with a state even though it does
not maintain a permanent establishment in that state
⢠P.L. 86â272 does not protect nonâU.S. companies
⢠Other forms of taxation
⢠Nonâincome taxes are generally not subject to treaties
State Taxation of NonâU.S. Businesses
Voluntary Disclosure
29. 2013 Praxity International Tax Conference
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⢠Almost all states allow a taxpayer with an exposure for current
and prior period taxes to come forward and pay tax under a
voluntary disclosure agreement
⢠Most will waive penalties, some will waive interest
⢠Most will limit the look back period to 3â6 years
⢠Most require the taxpayer not be registered with the state or to
have not received notices from the state (some exceptions here)
ever or at least within the last year
⢠Most require a third party to represent the taxpayer through the
process
⢠The taxpayer remains anonymous until an agreement is reached
⢠Careful if your client has collected and not remitted sales tax
State Voluntary Disclosure
Voluntary Disclosure
30. 2013 Praxity International Tax Conference
Atlanta
AGENDA
⢠Objectives
⢠Nexus
⢠Income Tax
⢠Sales & Use Tax
⢠Property Tax
⢠Credits & Incentives
⢠Voluntary Disclosure Agreements
⢠Parting Thoughts
31. 2013 Praxity International Tax Conference
Atlanta
⢠Before your client starts doing business in the United States:
⢠Consult with a U.S. state & local tax advisor.
⢠Depending on where they locate their business, they may pay state tax on 0% to over 200%
of their net income.
⢠If your client is already doing business in the United States:
⢠They are likely not filing where they need to. They should consider completing a nexus
study & exposure analysis. State auditors are aggressively looking for exposures.
⢠If selling a product that requires customs or other state inspection, make sure they are filing
sales tax returns. States are vigorously cross referencing activities to locate unregistered
taxpayers selling into their states.
⢠Most companies are doing something that qualifies for a credit or incentive. Many times the
opportunity to claim these incentives is lost if they do not prequalify for incentive.
⢠If they have known exposures, consider voluntary disclosure over amnesty.
⢠Think about a reverse audit of sales & transaction taxes paid if substantial property in US.
⢠Have an expert review any response to state phishing letters.
Parting Thoughts
32. 2013 Praxity International Tax Conference
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Rob OâNeill, Partner
Moss Adams, LLP
State & Local Tax Practice
(503) 478â2339
rob.oneill@mossadams.com
Bob Reynolds, Partner
Moss Adams, LLP
State & Local Tax Practice
(916) 503â8138
bob.reynolds@mossadams.com