This session will cover state budget and fiscal matters and related-tax policy implications as well as an update on captive insurance companies, self procurement taxes and recent legislation.
The document proposes exempting uniformed services retirement pay from personal income tax in Montana. It argues this would attract retired military personnel to the state, bringing an influx of skilled workers and hundreds of millions of dollars in federal transfer funds. Exempting retirement pay would benefit military retirees, businesses, and the state through new jobs, tax revenues, and workforce skills. The proposal estimates $1.9 million in additional annual state income tax revenue from every 1,000 military retirees who move to Montana. It also notes few impacts on schools and social services since most retiree children will be adults and retiree incomes are stable.
The document discusses Nevada's struggle to fund its government as its reliance on tourism and gambling revenues is no longer sufficient. It introduced the Nevada Commerce Tax enacted in 2015 to address budget shortfalls, which is similar to a margin tax proposal voters rejected in 2014. The tax faces legal challenges for ignoring the will of the voters. The Modified Business Tax implemented in 2003 also does not fully solve Nevada's fiscal problems on its own.
This document provides information about tax-friendly states for retirees and discusses factors retirees should consider when deciding where to retire, such as state income taxes, treatment of Social Security and pension benefits, and other tax benefits. It also includes a section on retirement plan and IRA contribution limits for 2009. College costs and trends are discussed, noting the large annual increases in tuition and other expenses in recent years. A brief section on student debt levels concludes the document.
Covering trends in state and local taxes, we'll focus on the impact regarding income and franchise taxes whether from a compliance, controversy or tax planning perspective.
Seminar Best Year To Buy Sell (Ver2 Final)tjmeyer1234
The document discusses why 2012 may be the best year to buy or sell a business due to pending changes and uncertainties. It notes that current tax incentives are set to expire at the end of 2012, which would significantly increase taxes on income, capital gains, and estates. Increased regulation, litigation risks, national debt, healthcare costs, and economic uncertainty also contribute to a challenging business environment. Selling a business in 2012 allows owners to take advantage of more favorable tax rates and estate tax exemptions before their anticipated rise in 2013.
1. The document discusses several terms related to the current election year tax debate, including the "Bush tax cuts", the alternative minimum tax (AMT), the "Buffett rule", value added tax (VAT), and a flat tax.
2. It explains that the "Bush tax cuts" lowered federal income tax rates and capital gains/dividend tax rates that are set to expire at the end of 2012. The AMT is a separate tax system that more taxpayers could face if exemptions are not extended.
3. The "Buffett rule" proposes that millionaires pay at least the same tax rate as middle-income families. A VAT is a consumption tax assessed at each production
This newsletter from Cedar Point Financial Services provides information on upcoming interest rate hikes and how they could impact various financial products. It discusses how adjustable rate mortgages, credit cards, and variable rate student loans may be affected if interest rates rise. The newsletter recommends ways for readers to protect themselves, such as refinancing a mortgage, paying down credit card debt, and reviewing student loan terms. It also provides two articles on estate tax reform possibilities and the connection between health and personal finances.
This document discusses potential changes to federal income tax rates and capital gains tax rates in 2011, as well as a strategy married couples can use to maximize their Social Security benefits.
Specifically, it notes that unless Congress acts, federal income tax brackets and capital gains tax rates will revert to 2001 levels in 2011. This means higher rates of 25%, 28%, 33%, 36%, and 39.6% and a long-term capital gains rate of 20% for many. It also describes a "file-and-suspend" Social Security strategy where one spouse files for benefits at full retirement age to allow the other to receive spousal benefits, while delaying their own filing to earn delayed retirement credits up to age 70.
The document proposes exempting uniformed services retirement pay from personal income tax in Montana. It argues this would attract retired military personnel to the state, bringing an influx of skilled workers and hundreds of millions of dollars in federal transfer funds. Exempting retirement pay would benefit military retirees, businesses, and the state through new jobs, tax revenues, and workforce skills. The proposal estimates $1.9 million in additional annual state income tax revenue from every 1,000 military retirees who move to Montana. It also notes few impacts on schools and social services since most retiree children will be adults and retiree incomes are stable.
The document discusses Nevada's struggle to fund its government as its reliance on tourism and gambling revenues is no longer sufficient. It introduced the Nevada Commerce Tax enacted in 2015 to address budget shortfalls, which is similar to a margin tax proposal voters rejected in 2014. The tax faces legal challenges for ignoring the will of the voters. The Modified Business Tax implemented in 2003 also does not fully solve Nevada's fiscal problems on its own.
This document provides information about tax-friendly states for retirees and discusses factors retirees should consider when deciding where to retire, such as state income taxes, treatment of Social Security and pension benefits, and other tax benefits. It also includes a section on retirement plan and IRA contribution limits for 2009. College costs and trends are discussed, noting the large annual increases in tuition and other expenses in recent years. A brief section on student debt levels concludes the document.
Covering trends in state and local taxes, we'll focus on the impact regarding income and franchise taxes whether from a compliance, controversy or tax planning perspective.
Seminar Best Year To Buy Sell (Ver2 Final)tjmeyer1234
The document discusses why 2012 may be the best year to buy or sell a business due to pending changes and uncertainties. It notes that current tax incentives are set to expire at the end of 2012, which would significantly increase taxes on income, capital gains, and estates. Increased regulation, litigation risks, national debt, healthcare costs, and economic uncertainty also contribute to a challenging business environment. Selling a business in 2012 allows owners to take advantage of more favorable tax rates and estate tax exemptions before their anticipated rise in 2013.
1. The document discusses several terms related to the current election year tax debate, including the "Bush tax cuts", the alternative minimum tax (AMT), the "Buffett rule", value added tax (VAT), and a flat tax.
2. It explains that the "Bush tax cuts" lowered federal income tax rates and capital gains/dividend tax rates that are set to expire at the end of 2012. The AMT is a separate tax system that more taxpayers could face if exemptions are not extended.
3. The "Buffett rule" proposes that millionaires pay at least the same tax rate as middle-income families. A VAT is a consumption tax assessed at each production
This newsletter from Cedar Point Financial Services provides information on upcoming interest rate hikes and how they could impact various financial products. It discusses how adjustable rate mortgages, credit cards, and variable rate student loans may be affected if interest rates rise. The newsletter recommends ways for readers to protect themselves, such as refinancing a mortgage, paying down credit card debt, and reviewing student loan terms. It also provides two articles on estate tax reform possibilities and the connection between health and personal finances.
This document discusses potential changes to federal income tax rates and capital gains tax rates in 2011, as well as a strategy married couples can use to maximize their Social Security benefits.
Specifically, it notes that unless Congress acts, federal income tax brackets and capital gains tax rates will revert to 2001 levels in 2011. This means higher rates of 25%, 28%, 33%, 36%, and 39.6% and a long-term capital gains rate of 20% for many. It also describes a "file-and-suspend" Social Security strategy where one spouse files for benefits at full retirement age to allow the other to receive spousal benefits, while delaying their own filing to earn delayed retirement credits up to age 70.
Status of Estate and Gift Tax Law as of Jan 2010; planning opportunities in 2010; cautions and traps if retroactive estate tax passed in 2010; planning for 2011.
Webinar: Sales Tax Issues to Keep an Eye Out For!Withum
This document discusses sales tax issues and provides an overview of nexus rules and the impact of the Wayfair decision. It summarizes key sales tax concepts such as nexus, economic nexus, marketplace facilitators, and taxability of software. The document advises reviewing a company's existing and post-Wayfair nexus footprint, assessing taxability of products/services, considering technology needs, and preparing to register and comply with new state sales tax requirements.
President Obama was re-elected, setting the stage for difficult negotiations over expiring tax provisions. Key issues include the Bush-era tax cuts, automatic spending cuts, and over 50 expiring tax extenders. Obama supports allowing tax cuts to expire for higher incomes and increasing rates on capital gains and dividends for them. The fiscal cliff forces Congress to act by year-end on these issues.
Please take the opportunity to view this presentation on why there are positives out there in the market, while looking at those that still concern us!
The document discusses potential tax policy reforms in Texas to promote job growth. It argues that while Texas has had economic success with conservative policies, there is still room for improvement regarding taxes. It proposes limiting direct business taxes like the franchise tax, and limiting rising property taxes through measures like lowering the appraisal cap. The goal is to make Texas a low-tax job creation leader while other states face debt, taxes and regulation problems under liberal policies. Comprehensive analysis on these reform ideas will be published on the TCCRI website.
The document discusses potential changes to federal income tax rates and capital gains tax rates in 2011 if current tax relief provisions expire at the end of 2010, outlines strategies married couples can use to maximize their Social Security retirement and survivor benefits through filing and suspending benefits, and provides an overview of common estate planning techniques business owners can use to transfer their family business to children to minimize taxes, such as gifting, using a buy-sell agreement, or establishing a grantor retained annuity trust.
Implications of Tax Cuts on Commercial Real Estatekottmeier
The document discusses the implications of various tax cut scenarios on the commercial real estate industry. Extending current income tax cuts for two years is the most likely outcome and would cost between $200-500 billion. This could shift some commercial real estate transactions to 2010 due to potentially higher capital gains taxes in 2011. Limiting itemized deductions and changes to estate tax laws could also impact commercial real estate markets and property values. Both short-term and long-term tax cuts carry economic and public debt implications.
The American Taxpayer Relief Act of 2012:
1) Allowed Bush-era tax rates to expire for individuals earning over $400,000 and families over $450,000, raising their tax rate to 39.6%;
2) Permanently patched the AMT by increasing exemption amounts; and
3) Provided for a maximum 40% estate tax and $5 million exemption.
It effectively raised taxes for all by not extending a payroll tax cut and delayed mandatory spending cuts. Congress will revisit tax and spending policies when addressing the debt limit in February, with entitlement reforms and the "chained CPI" likely to be controversial topics.
The document is an introduction letter from the Montana Department of Revenue included with the 2008 Montana income tax booklet for estates and trusts. It thanks taxpayers for paying their taxes and explains how tax dollars support public services in Montana. It provides contact information for the Department of Revenue and an overview of the contents of the tax booklet.
This document summarizes key 2011 individual income tax changes and tips. It discusses expanded IRS Form 1099 reporting requirements, the loss of some tax credits, a 2% payroll tax cut, and Illinois increasing its income tax rate from 3% to 5%. It provides details on new Forms 1099-K and 8949 for reporting stock basis and sales. The document also outlines various tax credits, deductions, and rates that were extended through 2012, including the alternative minimum tax exemption amounts.
The brookings institution webinar covid 19 and the economyTatianaApostolovich
With more than 1,000 deaths, 3 million and counting unemployed, and no definite end in sight, the coronavirus has upended nearly every aspect of American life. In the last two weeks, the Federal Reserve and Congress scrambled to pass policies to mitigate what will be a very deep recession. Americans across the country are asking— what exactly is going on economically? Is the government responding effectively? How do we set ourselves up for economic recovery once the pandemic recedes? On Monday, March 30, Brookings hosted an online discussion on the current state of the economy, the federal response, and challenges for state and local governments. After the discussion, speakers answered questions from the audience. This was an exclusively virtual event that was streamed live on the Brookings website
This document is from Mike Adams, an attorney at Williams, McDaniel, Wolfe, and Womack law firm in Memphis, TN. It discusses estate planning strategies like wills, trusts, life insurance beneficiary designations, and asset protection. It notes that estate taxes can be avoided by proper planning and coordinating assets between a will and other documents. The document also highlights changes to Tennessee and federal estate tax laws and how to modify plans accordingly.
The Tax Cuts and Jobs Act of 2017 made significant changes to the US tax code that will impact taxpayers. It lowered tax rates for individuals and doubled the standard deduction. However, it also capped state and local tax deductions, eliminated miscellaneous deductions, and increased the child tax credit. The act is temporary and many provisions will expire after 2025. Taxpayers need to check their withholding and adjust their W-4 forms to avoid underpayment of taxes owed or overpayment resulting in smaller refunds.
This document summarizes Rhode Island's budget presentation from December 2010. It provides information on revenues, expenditures, major budget drivers from 1995 to 2012 such as increases in human services and education costs. It also discusses revenues sources like personal income tax, sales tax, and lottery transfers. Expenditures by department and fiscal year are shown. Information on state employee compensation and full time employees is also included.
Updated version of our popular PowerPoint presentation that clearly and succinctly lays out the fiscal challenge facing the United States. To see what can be done about it, visit http://crfb.org/go-big
This document provides an overview of Chapter 3 and its exhibits on individual taxation. It includes 15 exhibits that cover topics such as the federal tax formula, definitions of gross income and adjusted gross income, personal and dependency exemptions, standard deductions, itemized deductions, filing status requirements, tax rates and schedules, self-employment taxes, and special rules for dependents. The exhibits provide definitions, examples, and criteria for key concepts in individual income taxation.
The document discusses the rise in US national debt from 1980 to present day. It attributes much of the increased debt to tax cuts under Reagan in the 1980s that reduced revenues and increased military spending. The debt continued rising under subsequent Republican administrations due to tax cuts and lack of fiscal responsibility. The debt decreased under Clinton but rose sharply again under George W. Bush due to increased military spending and tax cuts. The document argues for reducing military spending and entitlement programs, increasing taxes on the wealthy, and paying down the national debt to improve the country's fiscal health.
This panel will discuss the latest developments with the IRS including Large Business & International (LB&I) organizational changes and how they affect you.
How do CPAs stay ahead of the rapidly changing environment? Maryland Association of CPAs offer free four (4) hour professional issues updates for our members every six months.
These engaging and interactive "town hall" format meetings cover the latest developments facing CPAs. The Fall series features updates on the four mega-trends - Economy, Gobalization, technology and the Workforce. In aaddition the latest developments in Regulations and Standards are covered. This edition features many tax and IRS developments (PTIN, 1099) and the latest on financial accounting standards (IFRS, private companies).
We clsoe with a session on leadership in rapidly changing times.
Status of Estate and Gift Tax Law as of Jan 2010; planning opportunities in 2010; cautions and traps if retroactive estate tax passed in 2010; planning for 2011.
Webinar: Sales Tax Issues to Keep an Eye Out For!Withum
This document discusses sales tax issues and provides an overview of nexus rules and the impact of the Wayfair decision. It summarizes key sales tax concepts such as nexus, economic nexus, marketplace facilitators, and taxability of software. The document advises reviewing a company's existing and post-Wayfair nexus footprint, assessing taxability of products/services, considering technology needs, and preparing to register and comply with new state sales tax requirements.
President Obama was re-elected, setting the stage for difficult negotiations over expiring tax provisions. Key issues include the Bush-era tax cuts, automatic spending cuts, and over 50 expiring tax extenders. Obama supports allowing tax cuts to expire for higher incomes and increasing rates on capital gains and dividends for them. The fiscal cliff forces Congress to act by year-end on these issues.
Please take the opportunity to view this presentation on why there are positives out there in the market, while looking at those that still concern us!
The document discusses potential tax policy reforms in Texas to promote job growth. It argues that while Texas has had economic success with conservative policies, there is still room for improvement regarding taxes. It proposes limiting direct business taxes like the franchise tax, and limiting rising property taxes through measures like lowering the appraisal cap. The goal is to make Texas a low-tax job creation leader while other states face debt, taxes and regulation problems under liberal policies. Comprehensive analysis on these reform ideas will be published on the TCCRI website.
The document discusses potential changes to federal income tax rates and capital gains tax rates in 2011 if current tax relief provisions expire at the end of 2010, outlines strategies married couples can use to maximize their Social Security retirement and survivor benefits through filing and suspending benefits, and provides an overview of common estate planning techniques business owners can use to transfer their family business to children to minimize taxes, such as gifting, using a buy-sell agreement, or establishing a grantor retained annuity trust.
Implications of Tax Cuts on Commercial Real Estatekottmeier
The document discusses the implications of various tax cut scenarios on the commercial real estate industry. Extending current income tax cuts for two years is the most likely outcome and would cost between $200-500 billion. This could shift some commercial real estate transactions to 2010 due to potentially higher capital gains taxes in 2011. Limiting itemized deductions and changes to estate tax laws could also impact commercial real estate markets and property values. Both short-term and long-term tax cuts carry economic and public debt implications.
The American Taxpayer Relief Act of 2012:
1) Allowed Bush-era tax rates to expire for individuals earning over $400,000 and families over $450,000, raising their tax rate to 39.6%;
2) Permanently patched the AMT by increasing exemption amounts; and
3) Provided for a maximum 40% estate tax and $5 million exemption.
It effectively raised taxes for all by not extending a payroll tax cut and delayed mandatory spending cuts. Congress will revisit tax and spending policies when addressing the debt limit in February, with entitlement reforms and the "chained CPI" likely to be controversial topics.
The document is an introduction letter from the Montana Department of Revenue included with the 2008 Montana income tax booklet for estates and trusts. It thanks taxpayers for paying their taxes and explains how tax dollars support public services in Montana. It provides contact information for the Department of Revenue and an overview of the contents of the tax booklet.
This document summarizes key 2011 individual income tax changes and tips. It discusses expanded IRS Form 1099 reporting requirements, the loss of some tax credits, a 2% payroll tax cut, and Illinois increasing its income tax rate from 3% to 5%. It provides details on new Forms 1099-K and 8949 for reporting stock basis and sales. The document also outlines various tax credits, deductions, and rates that were extended through 2012, including the alternative minimum tax exemption amounts.
The brookings institution webinar covid 19 and the economyTatianaApostolovich
With more than 1,000 deaths, 3 million and counting unemployed, and no definite end in sight, the coronavirus has upended nearly every aspect of American life. In the last two weeks, the Federal Reserve and Congress scrambled to pass policies to mitigate what will be a very deep recession. Americans across the country are asking— what exactly is going on economically? Is the government responding effectively? How do we set ourselves up for economic recovery once the pandemic recedes? On Monday, March 30, Brookings hosted an online discussion on the current state of the economy, the federal response, and challenges for state and local governments. After the discussion, speakers answered questions from the audience. This was an exclusively virtual event that was streamed live on the Brookings website
This document is from Mike Adams, an attorney at Williams, McDaniel, Wolfe, and Womack law firm in Memphis, TN. It discusses estate planning strategies like wills, trusts, life insurance beneficiary designations, and asset protection. It notes that estate taxes can be avoided by proper planning and coordinating assets between a will and other documents. The document also highlights changes to Tennessee and federal estate tax laws and how to modify plans accordingly.
The Tax Cuts and Jobs Act of 2017 made significant changes to the US tax code that will impact taxpayers. It lowered tax rates for individuals and doubled the standard deduction. However, it also capped state and local tax deductions, eliminated miscellaneous deductions, and increased the child tax credit. The act is temporary and many provisions will expire after 2025. Taxpayers need to check their withholding and adjust their W-4 forms to avoid underpayment of taxes owed or overpayment resulting in smaller refunds.
This document summarizes Rhode Island's budget presentation from December 2010. It provides information on revenues, expenditures, major budget drivers from 1995 to 2012 such as increases in human services and education costs. It also discusses revenues sources like personal income tax, sales tax, and lottery transfers. Expenditures by department and fiscal year are shown. Information on state employee compensation and full time employees is also included.
Updated version of our popular PowerPoint presentation that clearly and succinctly lays out the fiscal challenge facing the United States. To see what can be done about it, visit http://crfb.org/go-big
This document provides an overview of Chapter 3 and its exhibits on individual taxation. It includes 15 exhibits that cover topics such as the federal tax formula, definitions of gross income and adjusted gross income, personal and dependency exemptions, standard deductions, itemized deductions, filing status requirements, tax rates and schedules, self-employment taxes, and special rules for dependents. The exhibits provide definitions, examples, and criteria for key concepts in individual income taxation.
The document discusses the rise in US national debt from 1980 to present day. It attributes much of the increased debt to tax cuts under Reagan in the 1980s that reduced revenues and increased military spending. The debt continued rising under subsequent Republican administrations due to tax cuts and lack of fiscal responsibility. The debt decreased under Clinton but rose sharply again under George W. Bush due to increased military spending and tax cuts. The document argues for reducing military spending and entitlement programs, increasing taxes on the wealthy, and paying down the national debt to improve the country's fiscal health.
This panel will discuss the latest developments with the IRS including Large Business & International (LB&I) organizational changes and how they affect you.
How do CPAs stay ahead of the rapidly changing environment? Maryland Association of CPAs offer free four (4) hour professional issues updates for our members every six months.
These engaging and interactive "town hall" format meetings cover the latest developments facing CPAs. The Fall series features updates on the four mega-trends - Economy, Gobalization, technology and the Workforce. In aaddition the latest developments in Regulations and Standards are covered. This edition features many tax and IRS developments (PTIN, 1099) and the latest on financial accounting standards (IFRS, private companies).
We clsoe with a session on leadership in rapidly changing times.
The document discusses the US fiscal cliff and tax policies. It notes that US government deficit projections depend on interest rates, economic growth, capital investment, and demographics. Currently, payroll and income taxes make up the largest sources of government revenue. The document also examines topics like income inequality, effective tax rates on the wealthy, taxes as a percentage of GDP compared to other countries, and projections of future revenues and deficits under different policy scenarios. It argues that reforming the tax code and linking taxes more closely to economic activity are needed to address budget issues.
Prepare for New Medicare Taxes & Other Potential Tax IncreasesCBIZ, Inc.
The combined effect of the new Medicare taxes contained in the health care reform law with the expiration of the “Bush Tax Cuts” has created what some pundits are calling “Taxmageddon.” Here is a summary of these potential tax increases, how they will affect you, and some ideas of how to mitigate the impact.
The document summarizes how the Affordable Care Act (ACA) affects Medicaid expansion and issues for reporters covering it. Key points include: the ACA expands Medicaid eligibility to 133% of the federal poverty level starting in 2014; full federal funding is provided for newly eligible individuals from 2014-2016; and the Supreme Court ruled that states cannot be penalized for declining the Medicaid expansion. The expansion is estimated to reduce the number of uninsured by nearly half if all states participate. Issues discussed include the costs and health impacts of expansion, eligibility systems, programs for dual eligibles, and reductions in safety net hospital funding.
Preparation is the Difference Maker! Post-Election Year-End Tax Planning WebinarCitrin Cooperman
The webinar provided an overview of key year-end tax planning considerations in light of the potential policy changes under a Biden administration. It discussed strategies for individuals, trusts and estates, businesses, and international taxpayers. For individuals, it addressed accelerating bonuses and capital gains. For trusts and estates, it covered making large gifts before potential exemption reductions. For businesses, it summarized changes to tax rates and deductions. For international taxpayers, it discussed reforms to GILTI and penalties for moving jobs offshore. The presentation aimed to help participants identify tax planning opportunities before the end of the year.
The document summarizes the results of a survey of corporate tax directors on state tax issues. It finds that California and New York are viewed as having the least fair and predictable tax environments due to their aggressive pursuit of tax revenue through tactics like asserting nexus and discretionary authority. States are increasingly looking to tax out-of-state businesses through economic nexus rules and by taxing a higher percentage of revenues from sales. The sourcing of taxable income from services is also an ongoing challenge and area of litigation as states disagree on the cost of performance vs. market-based approaches.
This document provides an overview of issues affecting the accounting profession. It discusses increasing complexity in regulations, emerging technologies, and a changing workforce. The profession is working to develop new standards, expand mobility, and focus on continuous learning to help CPAs navigate these changes and remain trusted advisors.
Hear an in-depth discussion of emerging trends in the global and domestic tax controversy landscape, and learn leading practices for managing tax risks.
This document discusses North Carolina's tax policies and economic trends. It notes that while NC has a large economy, per capita income has fallen relative to the national average in recent decades despite economic development efforts. The sales tax base has narrowed as consumption patterns have changed. To maintain revenues, sales tax rates have increased. The document suggests modernizing NC's tax code to promote income growth, considering a broader sales tax base or reducing reliance on volatile income taxes.
The document discusses Vermont's fiscal challenges, including high taxes, growing spending outpacing revenue growth, stagnant private sector job growth, and an aging population. It argues Vermont needs to prioritize economic growth through private sector job creation to broaden its tax base, contain spending increases, and address its large unfunded liabilities to improve its long-term fiscal health.
What You Need to Know About SALT Cap WorkaroundsCBIZ, Inc.
One of the least popular provisions in the Tax Cuts and Jobs Act (TCJA) involves a $10,000 limitation on deductions for state and local taxes (SALT). To avoid the negative repercussions of the so-called SALT cap, many states have embraced the creation of elective taxes on pass-through entities (PTEs) to help business owners pay these taxes at the entity level rather than through personal tax returns. This article details what you need to know about the SALT cap workaround before deciding to apply it to your business’ situation.
Do I Pay North Dakota Taxes When Someone Leaves Me Money?Raymond German
The document discusses various taxes that may apply when an individual inherits money or assets from someone who has passed away. It states that in North Dakota, there is no state-level estate or inheritance tax. It also explains that the federal estate tax only applies to estates worth more than $5.43 million and that inherited assets and money are not considered taxable income.
The document discusses various topics related to taxes including notable quotes about taxes, the origins of the federal income tax in the US, different types of taxes, arguments about the burden of taxes and how tax rates have changed over time. It provides statistics showing that reducing tax rates in the past under certain presidents led to increased tax revenues and that the top income earners pay the majority of taxes in the US.
Fund Our Future Tax The Rich Invest In Our New Yorkstrongforall
This document proposes six bills as part of the "Invest in Our NY Act" to raise $51-75 billion annually. The bills would: 1) Create a progressive income tax system; 2) Tax investment income the same as wages; 3) Create an inheritance tax; 4) Tax billionaire fortunes and amend the constitution to allow a wealth tax; 5) Create a tax on financial transactions; 6) Offset corporate tax cuts from Trump. The proposals are aimed at taxing the wealthy and large corporations to generate revenue to invest in New York's economy and support services.
AAA National Conference - Everything you wanted to know about state CPA Socie...Tom Hood, CPA,CITP,CGMA
Top 10 reasons and resources for CPA Firms from State CPA Associations. Presentation to the AAA National Practice Management Conference in New Orleans by Tom Hood, CPA, Past President of national CPA-SEA (State Execustives Association) and President of the Maryland Association of CPAs
REMNTM is a privately held mortgage banking firm founded in 1989 with over 600 employees across the US. It has three business channels - Retail, Wholesale, and Consumer Direct. In 2011, REMN funded $2.32 billion in mortgages and issued over $2 billion in securities. It maintains over $300 million in warehouse capacity. REMN offers traditional and niche mortgage products through in-house processing, underwriting, and closing teams supported by training, technology, and marketing programs.
REMNTM is a privately held mortgage banking firm founded in 1989 with over 600 employees across the US. It has three business channels - Retail, Wholesale, and Consumer Direct. In 2011, REMN funded $2.32 billion in mortgages and issued over $2 billion in securities. It maintains over $300 million in warehouse capacity. REMN offers traditional and niche mortgage products and has a nationwide licensing presence.
Similar to State and local tax and insurance tax update (20)
The theme for this quarter is momentum meets uncertainty. The upward trend in crude oil, natural gas, LNG and refined product prices that began in Q1 continued into Q2. Crude oil markets began the quarter just below $100/bbl and have closed below that level on only two days since late April. As we begin Q3, there are increasing concerns about the health of the global economy and how that might affect oil and gas demand.
Quarterly analyst themes of oil and gas earnings, Q1 2022EY
Financial questions continued to attract the most attention of the analyst community, with major focus on how companies will respond to the war in Ukraine, elevated commodity prices and improved cash flows. Strategic questions focused on how the changing geopolitical environment will affect capital allocation in the short and long term. Operationally, all eyes were on the capacity of companies to step up asset utilization and bring new projects to market quickly. Explore the latest EY quarterly analysts themes.
EY Price Point: global oil and gas market outlook, Q2 | April 2022EY
The theme for this quarter is rearrangement. The loss, or potential loss, of Russian oil and gas supplies is forcing producers, refiners and traders to rethink the flow of crude oil and refined products from the wellhead to the gas pump in light of sanctions, potential sanctions and the risk of reputational damage. Countries, companies and consumers will all be searching for ways to adapt, and the outcome of the race to bring alternatives to market could alter the global energy landscape for years to come.
It is likely crude oil and LNG prices will remain elevated for some time. The process of diverting Russian oil through countries unwilling to sanction it will take time and there is little indication OPEC members are willing (or able) to increase production to make up for the loss of Russian crude. Spare capacity sat at 3.7 mbpd at the end of 2021, just above where it was in January 2020. Currently, sanctioned Venezuelan and Iranian production (about 3 mbpd below their peak) could fill the gap, but political and commercial obstacles remain. At today’s prices, US shale production is attractive, but the fastest the industry has been able to grow is between 1mbpd and 2mbpd per year. The LNG infrastructure was already stretched before the war in Ukraine and there is little prosect of finding new supplies soon.
As the largest buyer of Russian energy, Europe will be the epicenter. There is a deeply embedded bias there in favor for renewable energy, and the current crisis is certain to result in an all-out effort to accelerate the build-out of wind and solar power. The capacity to add new green energy is limited though by the project pipeline and supply chains for solar panels and wind turbines, and it is likely that much of the shortfall will be made up with the new LNG infrastructure.
EY Price Point: global oil and gas market outlookEY
As the last quarter of the second pandemic year draws to a close, we continue to see heightened contrast
between the medical and economic points of view. While COVID-19 cases are close to their all-time highs, so
are equity prices, and a leading investment bank declared (on 2 December, 2021 after the Omicron outbreak in South Africa) that it was “optimistic about the possibility of a vibrant 2022.” When news of the variant hit in
late November, the markets were rocked by the prospect of yet another round of local mobility restrictions and
an interrupted return to normal international travel patterns, on top of the Biden Administration’s announced
release of 50 million barrels of crude from the US Strategic Petroleum Reserve. So far though, with OPEC
standing by its planned gradual return to normal production, oil prices have stabilized, albeit below where they
were in mid-November. Henry Hub prices, always at the mercy of the weather, responded predictably to a
warmer-than-normal early winter in the US, falling from US$6.60/MMBtu in early October to below
US$4.00/MMBtu by mid-December. In Europe and Asia, following a short reprieve at the start of the quarter,
piped natural gas prices have spiked again on concerns triggered by Russian troop buildups on the Ukraine
border and uncertainties surrounding the Nordstream 2 pipeline. Looking forward, OPEC and the U.S. Energy
Information Administration (EIA) in their last forecasts of the year both projected that 2022 oil demand would
be above what we saw in 2019. Although time will tell if those forecasts are realized and other events could
intervene, the response to new virus outbreaks is well-practiced and the trade-off between public health and
economic reality has tipped toward a cautiously optimistic view.
EY Price Point: global oil and gas market outlook, Q2 April 2021EY
The theme for this quarter is governed. Apparent market balance at prices that could be sustainable is the product of calculated choices by market leaders and the cooperation of those who follow them. Economics played their customary role as well, with capital scarcity in North America taking about 2 million barrels per day out of the market, about half of the remaining gap in demand. While inventories are close to their pre-COVID-19 levels, there is still uncertainty. The resolution of the pandemic is in sight, but timing is unclear. Vaccine distribution in the US is having an impact but Europe is struggling to contain a third wave of infections. The taps have opened on economic stimulus, but it remains to be seen if policymakers have done enough or if they have overshot the mark.
The shape of the crude oil forward curve has fundamentally changed since the end of the last quarter. In late December of last year, the Brent forward curve was gradually increasing while today, the curve is backwardated. This is a clear sign that the market sees a short-term dynamic that is disconnected from the medium-to-long-term fundamentals. The lasting impact of the COVID-19 pandemic remains to be seen. While many have opined that COVID-19 marks a turning point in energy transition, the IEA recently released a five-year forecast of oil demand that shows steady growth, albeit at rates that are below historical expectations.
Gas markets are a paradox. At the Henry Hub and at LNG destinations, demand grows, investment lags and prices will occasionally attract attention. Traders, so far though, are unconvinced and futures prices don’t indicate imminent scarcity at any link in the value chain.
EY Price Point: global oil and gas market outlookEY
We enter 2021 on a note of cautious optimism for global health, the world economy, and the oil and gas markets. The first weeks of December brought approval in the US and the UK of the first of several COVID-19 vaccines. The speed with which vaccine development occurred is unprecedented, but certainly welcome. In the weeks following the early November announcement of 90+% effectiveness by the manufacturer of the first approved vaccine, the price of WTI crude oil increased by US$10/bbl to US$48/bbl, the highest level since early March. Sustainability hasn’t returned yet, and whatever time it takes to get the world to normal, it will take even longer for normalization within the oil and gas markets. Inventories remain at historically high levels and, optimistically, it will take until April before inventory returns to levels observed in the preceding five years. That’s an estimate, and there has obviously been some difficulty properly calibrating the expectations of how balance will return and how long it will take. In late November, OPEC met to adjust its output plans because of the anemic rebound in demand. In mid-December, the IEA lowered its demand forecast for 2021 due mostly to continued sluggishness in aviation fuel demand.
A mild winter has interrupted a recovery in North American natural gas prices after a run-up motivated by curtailed capital expenditures, upstream activity and production. After an initial meltdown, with cargo cancellations and dramatic price reversal, LNG markets have made a remarkable comeback, and the spread between Asia and Henry Hub has reached a level we haven’t seen in almost three years. It may be the case that interruption in FIDs has brought us to the cusp of a balance that can support reliable returns.
EY Price Point: global oil and gas market outlook (Q4, October 2020)EY
Oil and gas prices have recovered steadily from their lows and are relatively stable, but that stability is supported by the combination of purposeful withholding of production by oil-producing countries and economic stress on upstream independents. Oil prices closed the quarter roughly where they started it, while refining spreads were down slightly. LNG spreads were substantially higher at the end of Q3 than they were at the beginning of the quarter but are still roughly half of what is generally thought of as sustainable.
Going forward, the market will be looking closely at how the economy and demand respond to new developments with respect to a potential COVID-19 vaccine and the US election.
EY Price Point: global oil and gas market outlookEY
As we close the second quarter of 2020, in most of Europe and Asia, the first (and hopefully last) wave of the COVID-19 crisis appears to be abating. In the parts of the US where the virus hit early, the profile has largely matched Europe’s, while in other parts, the urge to reopen businesses has trumped the desire to contain the virus and uncertainty looms. In the developing world, the crisis has just begun, but without the economic headroom and resources necessary to contain it. As the crisis unfolded, the effect on oil and gas demand has been predictable but difficult to gauge precisely and therefore difficult to manage.
Oil prices have crept up steadily as production has been curtailed through coordinated action (OPEC+) and because of economic reality (unconventional oil in North America). That trend has been subject to momentary spasms when bad news hit the market. It would be understandable if traders were nervous, and it seems that they are. Although nowhere near where it was at the peak of the crisis, option implied volatility is still at historically high levels. Gas markets, without the benefit of coordination on the supply side, continue to deal with the market implications of storage at or near capacity. Interfuel competition in power generation has always provided something of a floor, but those lows have been, and will continue to be, tested.
Zahl der Gewinnwarnungen steigt auf RekordniveauEY
Immer mehr deutsche börsennotierte Unternehmen müssen ihre eigenen Umsatz- oder Gewinnprognosen nach unten korrigieren. Im ersten Quartal stieg die Zahl der Prognosekorrekturen auf ein neues Rekordniveau: Insgesamt 77 Gewinn- oder Umsatzwarnungen wurden registriert.
Die Corona-Krise trifft auch die Versicherungsbranche mit voller Wucht. Die Versicherer rechnen mit weniger Neugeschäft. Jeder Fünfte mit Personalabbau und Prämienerhöhungen.
Liquidity for advanced manufacturing and automotive sectors in the face of Co...EY
The document discusses the impacts of COVID-19 on the liquidity and cash management of advanced manufacturing and mobility companies. It notes that companies are searching for short-term solutions to issues securing liquidity to fund operations as the global economy falls due to actions taken in response to the pandemic. It provides an overview of various challenges companies may face, such as cash shortages, credit squeezes, supply chain disruptions, and reduced access to capital. The document also outlines some measures companies can take to enhance short-term liquidity.
IBOR transition: Opportunities and challenges for the asset management industryEY
This document provides an agenda and overview of a webinar discussing the IBOR transition for the asset management industry. The webinar covers topics such as the progress of the transition, impact on asset managers and products, perspectives from European central banking working groups, and how firms are migrating. It introduces the speakers and their topics. In addition, it provides background on the drivers for IBOR reform, timeline of key milestones, and summaries of transition progress for different jurisdictions.
Fusionen und Übernahmen dürften nach der Krise zunehmenEY
Folgt auf die Corona-Krise ein M&A-Boom? Laut Capital Confidence Barometer von #EY hoffen 40 Prozent der deutschen Unternehmen auf sinkende Bewertungen von Übernahmekandidaten.
EY Price Point: global oil and gas market outlook, Q2, April 2020EY
The first quarter of this year has seen some extraordinary events. As if chronic oversupply, prices stuck below sustainable levels, the looming energy transition, and investor pressure to decarbonize weren’t enough, our industry now faces a dramatic, but hopefully temporary, downturn in demand as a result of the ongoing COVID-19 outbreak.
Our Global Chemical Industry Leader Frank Jenner explores the trends and drivers that will shape the chemical industry of tomorrow in our latest Chemical Market Outlook.
Die Geschäftslage im Mittelstand hat sich leicht verschlechtert, ist in den meisten Branchen aber weiter überwiegend gut - die Einstellungsbereitschaft sinkt.
A toxic combination of 15 years of low growth, and four decades of high inequality, has left Britain poorer and falling behind its peers. Productivity growth is weak and public investment is low, while wages today are no higher than they were before the financial crisis. Britain needs a new economic strategy to lift itself out of stagnation.
Scotland is in many ways a microcosm of this challenge. It has become a hub for creative industries, is home to several world-class universities and a thriving community of businesses – strengths that need to be harness and leveraged. But it also has high levels of deprivation, with homelessness reaching a record high and nearly half a million people living in very deep poverty last year. Scotland won’t be truly thriving unless it finds ways to ensure that all its inhabitants benefit from growth and investment. This is the central challenge facing policy makers both in Holyrood and Westminster.
What should a new national economic strategy for Scotland include? What would the pursuit of stronger economic growth mean for local, national and UK-wide policy makers? How will economic change affect the jobs we do, the places we live and the businesses we work for? And what are the prospects for cities like Glasgow, and nations like Scotland, in rising to these challenges?
The Universal Account Number (UAN) by EPFO centralizes multiple PF accounts, simplifying management for Indian employees. It streamlines PF transfers, withdrawals, and KYC updates, providing transparency and reducing employer dependency. Despite challenges like digital literacy and internet access, UAN is vital for financial empowerment and efficient provident fund management in today's digital age.
In a tight labour market, job-seekers gain bargaining power and leverage it into greater job quality—at least, that’s the conventional wisdom.
Michael, LMIC Economist, presented findings that reveal a weakened relationship between labour market tightness and job quality indicators following the pandemic. Labour market tightness coincided with growth in real wages for only a portion of workers: those in low-wage jobs requiring little education. Several factors—including labour market composition, worker and employer behaviour, and labour market practices—have contributed to the absence of worker benefits. These will be investigated further in future work.
How Does CRISIL Evaluate Lenders in India for Credit RatingsShaheen Kumar
CRISIL evaluates lenders in India by analyzing financial performance, loan portfolio quality, risk management practices, capital adequacy, market position, and adherence to regulatory requirements. This comprehensive assessment ensures a thorough evaluation of creditworthiness and financial strength. Each criterion is meticulously examined to provide credible and reliable ratings.
Solution Manual For Financial Accounting, 8th Canadian Edition 2024, by Libby...Donc Test
Solution Manual For Financial Accounting, 8th Canadian Edition 2024, by Libby, Hodge, Verified Chapters 1 - 13, Complete Newest Version Solution Manual For Financial Accounting, 8th Canadian Edition by Libby, Hodge, Verified Chapters 1 - 13, Complete Newest Version Solution Manual For Financial Accounting 8th Canadian Edition Pdf Chapters Download Stuvia Solution Manual For Financial Accounting 8th Canadian Edition Ebook Download Stuvia Solution Manual For Financial Accounting 8th Canadian Edition Pdf Solution Manual For Financial Accounting 8th Canadian Edition Pdf Download Stuvia Financial Accounting 8th Canadian Edition Pdf Chapters Download Stuvia Financial Accounting 8th Canadian Edition Ebook Download Stuvia Financial Accounting 8th Canadian Edition Pdf Financial Accounting 8th Canadian Edition Pdf Download Stuvia
STREETONOMICS: Exploring the Uncharted Territories of Informal Markets throug...sameer shah
Delve into the world of STREETONOMICS, where a team of 7 enthusiasts embarks on a journey to understand unorganized markets. By engaging with a coffee street vendor and crafting questionnaires, this project uncovers valuable insights into consumer behavior and market dynamics in informal settings."
2. Elemental Economics - Mineral demand.pdfNeal Brewster
After this second you should be able to: Explain the main determinants of demand for any mineral product, and their relative importance; recognise and explain how demand for any product is likely to change with economic activity; recognise and explain the roles of technology and relative prices in influencing demand; be able to explain the differences between the rates of growth of demand for different products.
South Dakota State University degree offer diploma Transcriptynfqplhm
办理美国SDSU毕业证书制作南达科他州立大学假文凭定制Q微168899991做SDSU留信网教留服认证海牙认证改SDSU成绩单GPA做SDSU假学位证假文凭高仿毕业证GRE代考如何申请南达科他州立大学South Dakota State University degree offer diploma Transcript
Fabular Frames and the Four Ratio ProblemMajid Iqbal
Digital, interactive art showing the struggle of a society in providing for its present population while also saving planetary resources for future generations. Spread across several frames, the art is actually the rendering of real and speculative data. The stereographic projections change shape in response to prompts and provocations. Visitors interact with the model through speculative statements about how to increase savings across communities, regions, ecosystems and environments. Their fabulations combined with random noise, i.e. factors beyond control, have a dramatic effect on the societal transition. Things get better. Things get worse. The aim is to give visitors a new grasp and feel of the ongoing struggles in democracies around the world.
Stunning art in the small multiples format brings out the spatiotemporal nature of societal transitions, against backdrop issues such as energy, housing, waste, farmland and forest. In each frame we see hopeful and frightful interplays between spending and saving. Problems emerge when one of the two parts of the existential anaglyph rapidly shrinks like Arctic ice, as factors cross thresholds. Ecological wealth and intergenerational equity areFour at stake. Not enough spending could mean economic stress, social unrest and political conflict. Not enough saving and there will be climate breakdown and ‘bankruptcy’. So where does speculative design start and the gambling and betting end? Behind each fabular frame is a four ratio problem. Each ratio reflects the level of sacrifice and self-restraint a society is willing to accept, against promises of prosperity and freedom. Some values seem to stabilise a frame while others cause collapse. Get the ratios right and we can have it all. Get them wrong and things get more desperate.
1. 22nd Annual Health Sciences
Tax Conference
State and local tax and insurance tax update
December 5, 2012
2. Disclaimer
► Any US tax advice contained herein was not intended or
written to be used, and cannot be used, for the purpose of
avoiding penalties that may be imposed under the Internal
Revenue Code or applicable state or local tax law
provisions.
Page 2 State and local tax and insurance tax update
4. Presenters
► Kelvin Ault ► Brad Withrow
Sr. Vice President of Tax Ernst & Young LLP
Vanguard Health Systems Nashville, TN
Nashville, TN +1 615 252 2050
brad.withrow@ey.com
► Troy Deason
Sr. Manager, State Income Tax
HCA Inc. ► Kevin Owens
Nashville, TN Ernst & Young LLP
Washington, DC
+1 202 327 8828
kevin.owens@ey.com
Page 4 State and local tax and insurance tax update
6. Election 2012 — federal races
► Why is federal outcome important for state taxes?
► Presidential, Senate and House Races
► Head of the ticket — effect on state races
► Federal tax reform and tax law changes affect state taxes
► Federal legislation to limit state taxes
► Remote seller sales tax; nonresident withholding
► Supreme Court appointments
► Constitutional issues on state tax cases
Page 6 State and local tax and insurance tax update
7. Election 2012 — state races
Ballot initiatives — tax
► Proposition 30 (Governor Brown)
► ¼¢ increase in sales tax rate
► Up to 2.5% increase in personal income tax rates
on those making US$250k or more
► California’s highest marginal rate is now
13.3% (NYC: 12.696%)
California ► Retroactive to January 1, 2012
► Business share of temporary CA sales tax
increase may be as high as US$650m per year for
four years
► CA personal income tax increase on
business income
Yes 53.9% No 46.1%
Precincts reporting: 98.5%
Page 7 State and local tax and insurance tax update
8. Election 2012 — state races
Ballot initiatives — tax
► Proposition 39 (co-chair Tom Steyer)
► Mandatory single-sales factor
► Incremental monies raised dedicated to funding
clean energy investments
► Estimated cost to business of mandatory single
sales factor apportionment = +US$1b/yr.
California ► Questions:
► Complications with respect to Gillette Co. and
Multistate Tax Compact election. (Can taxpayers still elect
three-factor?)
► Alternative sales sourcing?
► Can California reduce rates if revenues are greater
than anticipated?
Yes 60.1% No 39.9%
Precincts Reporting: 98.5%
Page 8 State and local tax and insurance tax update
9. Election 2012 — state races
Governors races
► Governors races
► Only 12 state governors races in 2012
► Most states have governors races in “off-Presidential” year to avoid influence at
top of the ticket (Wisconsin Governor Walker (R)
survived recall)
► North Carolina
► Only state with a party change
► Governor, Senate and House now in Republican control
► Key retirements in the Department of Revenue (DOR) in the past month or so
► Strong possibility for tax reform, including potentially:
► Broadened base, lower tax rate, simplified franchise tax/business license fee, push to
eliminate personal and corporate income taxes
► Looking ahead to 2013 elections
► New Jersey — Chris Christie (R) and Virginia — Bob McDonnell (R)
Page 9 State and local tax and insurance tax update
10. Pre-2012 election: who controls state
governments?
Republicans Democrats Split
WA
MT VT ME
ND
MN
OR ID
NH
SD WI NY
WY MI
IA PA CT MA
NE
NV OH
IN NJ RI
UT IL
CA CO WV DE MD
VA
KS MO
KY
NC
TN
AZ OK
NM AR
SC
AK AL GA
MS
TX
LA
HI
FL
Source: Multistate Associates.
Page 10 State and local tax and insurance tax update
11. Post-2012 election: who controls state
governments?
Republicans Democrats Split
Republicans gain Democrats gain
WA
MT VT ME
ND
MN
OR ID
NH
SD WI NY
WY MI
IA PA CT MA
NE
NV OH
IN NJ RI
UT IL
CA CO WV DE MD
VA
KS MO
KY
NC
TN
AZ OK
NM AR
SC
AK AL GA
MS
TX
LA
HI
FL
Only 12 legislative
houses changed
from 2012
Source: Multistate Associates.
Page 11 State and local tax and insurance tax update
12. 2010 composition of state legislatures
Republicans held both houses Democrats held both houses
Control is split
WA
MT ME
ND
MN
OR ID NY
SD WI
VT
WY MI
NH
IA PA CT
NV NE* OH MA
IN NJ
UT IL
RI
CA CO WV DE
VA
KS MO MD
KY
NC
TN
AZ OK
NM AR
SC
AK AL GA
MS
TX
LA
HI
FL
Source: National Conference of State Legislatures (NCSL). * Nebraska has a non-partisan state legislature.
Page 12 State and local tax and insurance tax update
13. 2012 post-election composition of state
legislatures
Republicans held both houses Democrats held both houses
Control is split
WA
MT ME
ND
MN
OR ID
SD WI NY VT
WY MI
NH
IA PA CT
NV NE* OH MA
IN NJ
UT IL
RI
CA CO WV DE
VA
KS MO MD
KY
NC
TN
AZ OK
NM AR
SC
AK AL GA
MS Dems. pick up four
TX states; GOP picks
LA
HI
up three states
FL
Source: NCSL. * Nebraska has a non-partisan state legislature.
Page 13 State and local tax and insurance tax update
14. 2012 post-election supermajorities
Republicans supermajority both houses Democrats supermajority both houses
Republicans supermajority one house Democrats supermajority one house
Supermajority —
more than 2/3rds
WA
vote of a
legislative house MT ME
ND
OR MN
ID NY
SD WI
VT
WY MI
NH
IA PA CT
NV NE* OH MA
IN NJ
UT IL
RI
CA CO WV DE
VA
KS MO MD
KY
NC
TN
AZ OK
NM AR
SC
AK AL GA
MS
TX LA
HI
FL
* Nebraska has a non-partisan state legislature.
Page 14 State and local tax and insurance tax update
15. States where one party has “supermajority”
legislative control
► 2/3 Republican control of both ► 2/3 Democratic control of both
chambers: chambers
► Indiana ► California
► Idaho ► Hawaii
► Kansas ► Massachusetts
► Missouri ► Rhode Island
► North Dakota ► 2/3 Democratic control of one
► Oklahoma
chamber
► South Dakota
► Illinois
► Tennessee
► New York
► Utah
► Vermont
► Wyoming
► West Virginia
► 2/3 Republican control of one
chamber: ► Why is a supermajority significant?
► Alabama
► Satisfy constitutional requirements for
► Michigan 2/3rds vote of tax bills
► Ohio
► Amend state constitutions
► Virginia
► Pass legislation without debate
► Supermajorities don’t last forever
Page 15 State and local tax and insurance tax update
16. Business tax issues being addressed
► Sales tax on business inputs
► Taxation of tangible personal property
► Growing importance of intangibles: property factor,
sourcing, property tax base
► Business tax competitiveness
► Effectiveness of incentives: transparency and targeting
► Effective tax rates for combined state-local business taxes,
including corporate income taxes
Page 16 State and local tax and insurance tax update
17. States considering tax reform
► Connecticut
► Business tax task force recommends phase-out of
corporate income tax (CIT) surcharge, minimum CIT
and business-entity tax
► North Carolina
► Lower the corporate tax rate and expand the sales/use
tax base to include various services
► New York
► Governor Cuomo (D) is set to announce members of
NY State Tax Reform and Fairness Commission
► Governor wants “revenue-neutral” tax reform that
increases economic growth
Page 17 State and local tax and insurance tax update
18. States considering tax reform
► Iowa
► Governor Branstad (D) proposing income and property tax cuts for
businesses and individuals — 2012 revenues exceeded forecasts by
US$260m
► Wants to use revenue to make Iowa “more competitive” and reduce
“job killing” property taxes
► Kentucky (Blue Ribbon Commission)
► Goal: shift taxes from business capital and labor income to
consumption
► Broaden sales tax base, but “tax B-to-B less and tax consumption
more”; option of local sales tax
► Major reform option: replace CIT with gross receipts tax
► Other: eliminate tangible personal property (TPP) tax, adopt single
sales factor (SSF) with destination sales
Page 18 State and local tax and insurance tax update
20. Recent events
► Ascension Health forms joint venture with Oak Hill Capital
Partners to acquire hospitals in a taxable platform.
► Ascension Health partners with India-based Narayana
Hrudayalaya Hospitals to build US$2 billion health
campus in Grand Cayman.
► Mayo Clinic, NYU Hospitals and Dignity Health have
issued US$1.1 billion in taxable bonds.
► Caritas Christi converts to investor-owned status via
acquisition by Cerberus Capital.
► Detroit Medical Center is acquired by Vanguard.
Page 20 State and local tax and insurance tax update
21. Related articles
► “Illinois hospital tax break costs $10M, could help
MetroSouth,” Southland News, November 9, 2012
► “State may put non-profit hospitals on tax rolls, with
incentives,” ChicagoBusiness.com, November 29, 2011
► “Non-profits no better on charity care,”
ChicagoBusiness.com, October 19, 2009
► “Much is given by hospitals, more is asked,” Boston
Sunday Globe, May 31, 2009
► “Real Property Tax Exemptions at Risk,” Taxation of
Exempts (WG&L Journals), 2008
Page 21 State and local tax and insurance tax update
23. Illinois charity care credit
► Income tax credit equal to the lesser of
► Property taxes on hospital parcel
Or
► Cost of charity care provided
► Effective for tax years ending on or after December 31, 2012
► Credit may be transferred or carried forward for five years
► Initially discussed as an offset to 2007 gross receipts tax proposal, then
ultimately enacted as part of grand compromise with hospitals on Medicaid
and non-profit hospital tax exemption in 2012 spring legislative session
► Some legislators were initially proposing to tax all hospitals
► Possible constitutional challenges to legislation in light of
Provena decision
► Charity care credit is also subject to a sunset clause as are all Illinois tax credits
Page 23 State and local tax and insurance tax update
25. Medicare and Medicaid electronic health
record incentive programs
► Medicare incentive payments
► The American Recovery and Reinvestment Act of 2009 (ARRA), Pub. L. No.
111, sec. 4102(a) (Feb 17, 2009), amended Section 1886 of the Social
Security Act to establish incentive payments for certain eligible professionals
and hospitals participating in the Medicare Fee For Service (FFS) program
where they demonstrate “meaningful use” of certified electronic health records
(EHR) technology, beginning in 2011 and ending in 2016.
► Medicaid incentive payments
► Section 4201 of ARRA amended Section 1903 of the Social Security Act to
establish incentive payments for certain eligible professionals and hospitals
participating in the Medicaid program to “purchase, implement, operate
(including support services and training for staff) and meaningfully use”
certified EHR technology, beginning in 2011 and ending in 2021.
► Eligible hospitals may receive both incentives as long as they meet
requirements of each program.
Page 25 State and local tax and insurance tax update
26. State tax issues: EHR incentives receipts
► State income tax implications of the incentives receipts
► Federal income tax treatment conformity
► Separate entity-level treatment/allocation
► Tax base and apportionment impact
► Receipts factor inclusion
► Receipts factor sourcing
► Receipts from federal government
► State and local receipts-based taxes and related
implications of the incentives receipts
► Definition of taxable receipt
► Sourcing
► Offsets, exemptions, receipts from federal government
Page 26 State and local tax and insurance tax update
27. State tax issues: EHR expenditures
► Sales tax issues related to multistate hardware and
software costs
► Credit and incentive opportunities related to EHR
expenditures
► Headquarter state opportunities
► Multistate opportunities related to expenditures at the facilities
► Consider any potential negative implications to credit and incentive
programs limited by government funding
► Property tax valuation issues
► Franchise tax implications
Page 27 State and local tax and insurance tax update
28. State tax nuances
► Texas margins tax
► Health care providers (100% exemption for government revenue)
► Health care institutions (50% exemption for government revenue)
► Administrative guidance
► Comptroller’s Ruling 200810212L (10/27/2008)
► Comptroller’s Ruling 201001990L (01/27/2010)
► Consider how your compliance group accumulates the data
► Others?
Page 28 State and local tax and insurance tax update
30. Introduction
► More and more states are focusing on nonresident withholding
► States are looking for money and many already have laws on
their books
► Nonresident withholding is becoming more highly scrutinized
► Exemptions/waivers
► Corporation signs waiver, indicating they will file/pay at corporate level
► Corporate owners often meet the exceptions to the requirements, but if
they fail to certify in writing, the states may go after the partnership for
failure to withhold
► ASC 740
► The pass-through entity is not subject to income tax but the entity is liable
for the nonresident withholding
► Consider characterization of income as an income tax at the partnership
level
Page 30 State and local tax and insurance tax update
31. Nonresident withholding: Georgia
► Georgia audit example
► Notification of audit
► Assessments at the partnership level
► Potential policy change (regarding penalty abatement)
► In this example, Georgia Department of Revenue appears
to be focusing more on this issue from a policy
perspective and may be less willing to waive penalties
Page 31 State and local tax and insurance tax update
32. Working in the clouds: state tax
considerations of cloud computing
33. Background
► Cloud computing is the delivery of shared resources, software and
information over a network or the internet which can be accessed by
computer or other devices.
► Users are typically not aware of the underlying technologies used to
provide the services (e.g., servers), only that the resources they wish
to purchase are available over the internet (the backbone of the
cloud).
► Cloud revenue growth is forecast to experience a 26% compound
annual growth rate between 2011 and 2014 — five times faster than
the IT industry as a whole.
► Cloud computing is borderless by nature but tax regulations and
compliance are not.
► Cloud computing gives rise to complex and potentially material tax
issues.
Page 33 State and local tax and insurance tax update
34. Cloud computing defined
The three primary service models of cloud computing are:
► Software as a Service (SaaS): applications both general, such as
word processing, email and spreadsheet, and specialized, such as
customer relationship management (CRM) and enterprise resource
planning (ERP). SaaS is sometimes referred to as hosted or
managed software, and the original offerings were from application
service providers (ASPs)
► Platform as a Service (PaaS): databases, development tools and
other components required to support the delivery of custom
applications
► Infrastructure as a Service (IaaS): raw computing power, storage
and network bandwidth
Page 34 State and local tax and insurance tax update
35. What’s happening now in the states?
► States try to expand existing law
► Legislative, judicial and regulatory developments occurred
at an increasing rate
► Most notably with respect to nexus and tax base
► Primary focus has been on sales and use taxes
► Convenient source of revenue
► Perception that it is less complicated and politically charged than going
after income-based taxes
Page 35 State and local tax and insurance tax update
36. Why have the issues become so prevalent
from a sales-tax perspective?
► Hosted software, “cloud” computing and ASP
► SaaS vs PaaS vs IaaS
► States still coming to grips with IaaS and PaaS
► IaaS as a rental of tangible personal property
► Historical treatment of SaaS
► Electronic delivery?
► Information service or database access?
► Another enumerated taxable/non-taxable service?
Page 36 State and local tax and insurance tax update
37. Sales tax on software
► Who is the “taxable person”?
► Is the vendor or the hosting company physically present in the
taxing state?
► Where are the data centers located?
► Where is the software housed?
► How are transactions sourced?
► Generally based on destination — where the customer
uses/accesses the software/service
► Customer multistate use exemption
► Difficult for vendor or hosting company to determine where
use occurs
► Streamlined sales tax (SST) sourcing rules
Page 37 State and local tax and insurance tax update
38. Sales tax on software: classification
determines taxability
► First consideration
► Canned
► “Off-the-shelf”
► Designed for multiple users
► Custom
► Designed for specific single user
► Modifications to canned software can be a gray area
► Second consideration: method of delivery
► Tangible format
► Electronic delivery
► ASP — also called SaaS or “in-demand software” or
“cloud computing”
► Load and leave/load and return
Page 38 State and local tax and insurance tax update
39. Sales tax on software: cloud computing
(ASP model)
► Is the transaction taxable?
► Look to state treatment of ASP/SaaS/cloud computing
► What does the customer receive?
► Access to software or access to infrastructure?
► State positions taken (note this is based on various levels of authority
and specific facts)
► Not taxable: AL, AR, CO, IL, KS, LA, ME, MS, NE, NV, NJ, OK, PA, RI,
TN, VA, WI
► Taxable: AZ, CT, HI, ID, IN, KY, MA, MI, NM, NY, SC, SD, TX, UT, VT,
WA, WV
► Other states that lack specific guidance may determine taxability by
treating transaction as:
► Sale/license of electronically delivered software
► Provision of “computer” services (e.g., data processing, information
services)
Page 39 State and local tax and insurance tax update
40. Sales tax on digital goods and services
► How are digital goods/services taxed?
► SST states
► Specified digital products
► Other products “transferred electronically”
► Non-SST states will tax based on classification
► Look to definition of “tangible personal property”
► Consider state sales and use tax treatment of service transactions
► Growing trend toward providing specific guidance and toward taxing
“digital equivalents”
► Is the digital good a software or a service? For example:
► New York — online games are taxable as “pre-written software”
► Texas — online games are taxable: “data processing,” “pre-written
software” or “amusement services”
Page 40 State and local tax and insurance tax update
41. Sales tax on digital goods and services
► What are digital goods/services?
► SST: “specified digital products” means electronically transferred:
► “Digital audio-visual works”
► “Digital audio works”
► “Digital books”
► Non-SST states will often look to agreement to determine
characterization of sales as:
► Tangible personal property
► Services
► Mixed transaction
► Something else
Page 41 State and local tax and insurance tax update
42. Sales tax on digital goods and services
► Federal
► The proposed law (The Digital Goods and Services Tax Fairness
Act of 2011, H.R. 1860/S. 971) would establish a national
framework for taxation of digital goods and services and prevent
retail sales of such products from being taxed by multiple states.
► The bill stops short of prescribing a specific system for how states
can tax sales of digital goods.
► It prohibits state and local governments from applying taxes to
those products that do not apply to similar tangible goods.
Page 42 State and local tax and insurance tax update
43. Sales tax sourcing issues
► Should transaction be sourced (i.e., taxing location) based
on:
► Location of the seller?
► Where SaaS is used?
► Some other location?
► Once the situs has been determined, a sales tax
determination can be made.
Page 43 State and local tax and insurance tax update
45. California
► S.B. 1015 (enacted June 27, 2012) — repeals all
provisions related to the Compact, effective immediately
► California no longer “sovereignty member” of Compact
► Not approved by 2/3rds vote of either house — Prop 26 problem?
► Doctrine of election — Legislative Counsel’s Digest — Legislature
“intended” that any election must be made on an originally
filed return
► Gillette (Cal. App. Ct.) — The 1993 law change mandating
that the double-weighted sales factor be used did not
repeal the Compact election and, therefore, taxpayers
were entitled to make the Compact election.
► The Compact is a valid compact that California as a signatory
state is bound by until the state withdraws from the Compact.
Page 45 State and local tax and insurance tax update
46. Other states
► Michigan
► H.B. 4479 (enacted May 25, 2011) — beginning January 1, 2011,
taxpayers cannot apportion/allocate income in accordance with the
Compact, but rather must use the method provided by the
Michigan Business Tax (MBT) and CIT.
► Litigation (IBM) is currently before the Court of Appeals on whether
the election is allowed under the MBT.
► Oregon
► ORS 314.606 specifically provides that when the Compact
provisions are inconsistent with the Uniform Division of Income for
Tax Purposes Act, the Oregon statutory provisions “shall control.”
► Litigation (HealthNet) is currently before the Tax Court.
Page 46 State and local tax and insurance tax update
47. Texas margins, Compact developments and
other updates
► In three recent rulings — Decision Nos. 106,503 (August 10, 2012), 106,298
(September 6, 2012) and 106,149 (September 11, 2012), the Comptroller of
Public Accounts continues to reject taxpayers’ use of the three-factor
apportionment formula under Article IV of the Compact.
► The Comptroller has determined that when apportioning taxable margin to Texas,
the taxpayer is required to use the single gross receipts factor provided under Tex.
Tax Code Ann. § 171.106(a).
► A taxpayer whose attempted use of the Compact’s three-factor formula was
rejected by the Comptroller is challenging the rejection and has filed a lawsuit in a
Texas district court (Graphic Packaging Corp. v. Combs, Doc. 2012-22096 (Tex.
Dist. Ct., Travis County, filed Oct 2012)).
► The Texas Supreme Court has held that the state franchise tax does not
violate the Texas Constitution’s Equal and Uniform Clause and the federal
Equal Protection, Due Process and Commerce Clauses. As an initial matter,
the court determined that it has original jurisdiction over challenges to the
constitutionality of the tax. (In re: Nestle USA, Inc., Tex. S. Ct., Dkt. No.
12-0518, 10/19/2012.)
Page 47 State and local tax and insurance tax update
49. State taxation of premiums
► Premium tax
► Assessed against admitted insurance company
► Based on premiums allocable to state
► Surplus lines
► Insurance company not licensed to sell insurance in state
► Insurance placed by lines broker with non-admitted company
► Surplus lines tax assessed against surplus lines broker
► Independently procured insurance
► Insured acquires insurance directly from non-admitted company
► Most states assess tax against insured
Page 49 State and local tax and insurance tax update
50. Independently procured insurance tax
► Imposed by a majority of states
► Statute varies state by state
► Historically, has not been rigorously enforced by most
states
► California, New York, Texas and Florida have been more active
► Generally applies when insurance is purchased from
non-admitted insurance company
► May apply to insurance from captive insurance companies as they
are only licensed in state of domicile
Page 50 State and local tax and insurance tax update
51. Pre-Dodd–Frank contracts in effect prior to
July 21, 2011
► The typical statute applies tax when insurance is procured
from an insurance company not admitted to do business
in the state.
► NYS: “There is hereby imposed on any person who purchases or
renews a taxable insurance contract from an insurer not authorized
to transact business in this state under a certificate of authority
from the superintendent of insurance …”
► CA: “Every person who effects insurance with a non-admitted
insurance carrier is required to pay a tax of 3% of net premiums.”
► The tax only applies to risks located in that state
Page 51 State and local tax and insurance tax update
52. Limitation on independently procured
insurance tax — Todd Shipyards
► Todd Shipyards 370 U.S. 451 (1962)
► A New York corporation did business and owned property
in Texas.
► All transactions regarding the insurance occurred outside of
Texas; the insurance was purchased, the premiums were paid,
and any claims were to be adjusted and paid in New York.
► The insurers were located in London, were not licensed in Texas,
had no agents in Texas and did no business in Texas.
► The broad Texas self-procurement statute contained no limitations
requiring actions in the state to give rise to the tax.
► The Supreme Court invalidated the tax levied.
► Texas tax may not be constitutionally imposed when the only
connection between the insurance transaction and the state is that the
insured risk is located in Texas.
Page 52 State and local tax and insurance tax update
53. Is Todd Shipyards still valid?
► Associated Electric & Gas Insurance Services, Ltd. 676
A.2d 1357 (RI 1996) AEGIS
► Premium taxes assessed by Rhode Island against Bermuda
insurance company
► Todd Shipyards had been superseded
► Dow Chemical Co. 38 S.W.3d 741 (Tex. Ct. App. 2001)
► Attempt by Texas to impose essentially the same self-procurement
tax statute at issue in Todd Shipyards
► Texas court rejected argument used in AEGIS
► Todd Shipyards still valid
Page 53 State and local tax and insurance tax update
54. Limitation on Todd Shipyards
► STP Nuclear Operating Company 239 S.W.3d 264 (Tex.
App. Austin 2007)
► Application of Texas Independently Procured Tax upheld
► Factual difference with Todd Shipyards
► Insured headquartered in Texas
► Supervisor of corporate insurance was located in Texas
► Direct communications via email and letters between the corporation
and the nonadmitted insurer
► Insurance contracts negotiated and approved by the corporation’s
employees in Texas
► Premium payments originated in Texas
► Losses were payable to insureds in Texas
Page 54 State and local tax and insurance tax update
55. Non-admitted and Reinsurance Reform Act
(NRRA)
► NRRA part of Dodd–Frank legislation
► Enacted into law in July 2010, with most provisions
effective July 21, 2011
► Reforms the taxation and regulation of insurance between
an insured and an insurance company
► Focuses on surplus lines but includes directly procured insurance
► Only the “home state” can tax or regulate insurance with a non-
admitted insurance company
► NRRA provides several key definitions
Page 55 State and local tax and insurance tax update
56. Key definitions
► Home state
► The state in which an insured maintains its principal place of
business
► If 100% of the insured risk is located out of that state, the state to
which the greatest percentage of the insured’s taxable premium for
that insurance contract is allocated (this method of allocation is
commonly referred to as the “cost of performance”)
► If there are more than one insureds from an affiliated group
identified as named insureds on a single non-admitted insurance
contract, the “home state” means the home state of the member of
the affiliated group that has the largest percentage of premium
attributed to it under such insurance contract. “Affiliated group”
means any group of entities that share common control. An
affiliated group may include entities that share parent-subsidiary
and/or brother-sister corporate relationships
Page 56 State and local tax and insurance tax update
57. Key definitions
► Independently procured insurance
► Insurance procured directly by an insured from a non-admitted insurer
► Non-admitted insurance
► Any property and casualty insurance permitted to be placed directly or
through a surplus lines broker with a non-admitted insurer eligible to
accept such insurance
► Non-admitted insurer
► An insurer not licensed to engage in the business of insurance in a
particular state. A non-admitted insurer does not include a risk retention
group, as defined in the Liability Risk Retention Act of 1986, 15 U.S.C.
3901(a)(4)
Page 57 State and local tax and insurance tax update
58. States adoption of NRRA
► Adoption of NRRA varies by state
► Generally, states have adopted NRRA definitions and
modified law to use those definitions
► States adopting NRRA definitions also tax 100% of
premiums, e.g., New York and Texas
► Prior to NRRA, generally only premiums allocable to state were
subject to tax
► Current status of tax is very confusing
► For example, Virginia has legislative procedure to collect tax but
has not placed tax on its books
► Not all states have adopted NRRA definitions, e.g., Alabama
Page 58 State and local tax and insurance tax update
59. States adoption of NRRA — reaction
► Vermont Captive Insurance Association
► White paper concludes that NRRA was not intended to apply to
captive insurance companies
► Does not address changes in state law
Page 59 State and local tax and insurance tax update
60. What to do
► Benchmark IPT
► Prepare analysis of location of risks being insured and premium
allocable to those locations
► Determine home state under NRRA
► Determine law of home state — does home state impose IPT?
► Determine if any risks are in states that have not adopted NRRA
► Planning considerations
► Re-domesticate captive to home state
► Control determination of home state, e.g., multiple contracts or
contracts with varying coverages
► Move insurance functions in order to invoke Todd Shipyards
► Possible legal arguments
► Contest tax on 100% of premiums on constitutional grounds
► Determine whether arrangement insurance is for IPT purposes
Page 60 State and local tax and insurance tax update
61. State income tax issues
► Consolidated returns
► Entity included by virtue of inclusion in federal consolidated return
► Consider income classification and possible non-business
treatment (e.g., investment income)
► Unitary returns
► Alaska and Idaho — sales factor based on premiums plus property
factor for investments
► New Hampshire — separate apportionment method and then
combine post-apportioned income with the group
► California — statutory exclusion
Page 61 State and local tax and insurance tax update
62. State income tax issues
► Partnership investments in insurance subs — NY example
► Aggregate basis — corporate entity combines its income, capital
and factors with its distributive share of the partnership’s income,
capital and factors
► Entity basis — corporation reports distributive share of partnership
income and capital but apportions based on the corporation’s
factors (favorable if the corporate partner’s NY apportionment
would be zero)
► Foreign corporate partner election — the corporate partner reports
its share of partnership income and capital as apportioned at the
partnership level
► Regulations governing this election may or may not apply to insurance
companies that are subject to Article 33. The regulations are
ambiguous on this point and the Department has informally granted
leeway with similar fact patterns
Page 62 State and local tax and insurance tax update
63. Partnership investments in insurance subs:
aggregate basis
► Aggregate theory must be used if any of the following apply:
► The corporate partner is conducting a unitary business with
the partnership
► The corporate partner is a general partner of the partnership or a managing
member of an LLC treated as a partnership
► The corporate partner has a 5% or greater interest in the partnership
► The partnership interest constitutes more than 50% of its
total assets
Or
► Any member of the corporate partner’s affiliated group has the information
necessary to perform an aggregate computation
► For this test, a corporate partner that receives a complete Form
IT-2-04-CP must file using the aggregate method
Page 63 State and local tax and insurance tax update