News
Executive Order Allows Tax Deferral of Social Security Tax for Employees
On August 9, 2020, President Trump signed an executive order that allows for the deferral of withholding, deposits, and payments of the employee portion of Social Security tax from September 1 to December 31, 2020. Further to this, on August 28, 2020 the Treasury issued Notice 2020-65 providing guidance on the implementation of President Trump’s…
KBF Adds Priyanka Shah to its CTS Practice
Please join us in welcoming Priyanka Shah to KBF. We are excited to announce the addition of Priyanka Shah, Tax Manager, to KBF in the Seattle Corporate Tax Services group. Priyanka will be working from her home office in Dallas, TX. Priyanka started her career with Deloitte Tax in New York in 2012 and moved…
Supreme Court Denies Review of Tax Breaks for Big Tech Companies in Altera but the Controversy Continues
The Supreme Court denied a petition of certiorari in Altera v. Commissioner on June 22, 2020, a closely followed case from the Ninth Circuit concerning the validity of a 2003 Treasury regulation requiring participants to include stock-based compensation (SBC) as intangible development costs (IDCs) in cost-sharing arrangements (CSAs). Altera argued that Treasury violated the Administrative…
KBF Adds Jie Shao to its CTS Practice
Please join us in welcoming Jie Shao to KBF. Jie Shao is joining KBF as an International Tax Director, where she will be focused on growing and developing our Corporate Tax Services practice. Jie is a firmwide resource and will be assisting clients in all of the markets KBF serves. Jie has 17-years of public…
Proposed Reliance Regulations on Disallowed Transportation and Commuting Expenses
Background As amended by the Tax Cuts and Jobs Act (TCJA), Internal Revenue Code (“IRC”) Section (“Sec.”) 274(a)(4) disallows deductions for the expense of any qualified transportation fringe (QTF) as defined in IRC Sec. 132(f) provided to an employee of the taxpayer for amounts paid or incurred after December 31, 2017. The value of a…
Temporary California Net Operating Loss Suspension Signed into Law
History California has at times either restricted the ability of individuals and corporations to utilize the full carryover amount of net operating losses (“NOLs”) or completely suspended net operating loss deductions for business entities and individuals with business income in response to facing budgetary constraints. For example, in response to the global mortgage crisis that…
Multnomah County Reviewing Two Tuition-Free Preschool Measures for November Ballot – Both Seek to Tax High-Earners
Multnomah County has two tuition-free preschool measures that may go to the ballot this November. The first campaign, Universal Preschool Now, has received enough signatures to be considered by the Multnomah County Board of Commissioners. This campaign has been developed by an independent task-force group. The other campaign, Preschool For All, is developed by a…
Seattle’s City Council Passes ‘JumpStart Seattle’ Payroll Tax on Big Businesses – Mayor Returns Bill Unsigned with New Proposals
Seattle’s City Council recently passed a 20-year tiered payroll tax on businesses with payrolls greater than $7 million. Mayor Jenny Durkan returned the bill to the City Council on July 17, 2020 unsigned, understanding it will become law. The city estimates that about 800 corporations will be subject to the tax, and it expects to…
Oregon Legislature Makes Changes to Corporate Activity Tax (CAT); Second Payment Deadline on July 31, 2020 Remains for Taxpayers
The Oregon Corporate Activity Tax (CAT) is imposed on taxpayers that have commercial activity of more than $1 million. Although many Oregon taxpayers have asked for significant changes to the CAT due to the economic downturn from COVID-19, the legislature only made changes that affect a small subset of taxpayers. The new legislation is beneficial to…
UPDATE: Portland Metro Council Votes to Refer Payroll Tax to November Ballot
On July 16, 2020, the Portland Metro Council unanimously voted to send a $7 billion transportation plan to the November ballot. This tax will impose a payroll tax on employers for individuals who perform services in the Metro Area. The rate will not exceed 0.75% of wages paid by the employer, and employers with 25 or…
The State of Wayfair in 2020: State and Local Income Tax Implications Two Years After the Wayfair Decision
In 2018, the U.S. Supreme Court overturned the long-standing physical presence standard for sales-and-use tax nexus in South Dakota v. Wayfair (“Wayfair”). Since then, nearly all states that impose sales and use tax have adopted economic nexus standards. Several states have started extending the economic nexus standard beyond sales tax regimes, adopting economic nexus provisions…
The Future of International Taxation: BEPS 2.0, DSTs, or What?
Even as regulatory guidance is still being issued by the U.S. Treasury, nearly 2-1/2 years after the enactment of sweeping changes to the international taxation of U.S.-based multinational enterprises (MNEs), the Organization for Economic Co-operation and Development (OECD) has been spearheading proposed changes to global taxation known as “BEPS 2.0” which would cause another seismic…