Some U.S. SaaS Companies now Subject to new Canadian “Economic Nexus” Sales Tax Compliance

Some U.S. SaaS Companies now Subject to new Canadian “Economic Nexus” Sales Tax Compliance

A cooling wind from the North Country may have been the fervent wish of many as relief from the heat waves blasting much of the U.S. this summer. Alas, only the cold, hard fact of yet another sales tax compliance burden has blown in to chill the bones of certain U.S. software companies selling to our neighbors in the north.This change comes just as companies are beginning to recover from the effects of U.S. sales...

Wayfair and Factor-Based Nexus for Income Tax: The New Two-Step

Wayfair and Factor-Based Nexus for Income Tax: The New Two-Step

You’ve likely heard the expression “waiting for the other shoe to drop.”  By some accounts, the origin of this phrase can be traced to early 20th century tenement buildings where bedrooms on one story were located directly atop those on the lower story.  You knew when your upstairs neighbor came home because you could hear her shoe drop.  This left you waiting for the sound from the drop of the other shoe.    So it is...

Tax Strategies for Tech Companies

Tax Strategy for Tech Companies

There’s never a dull moment in the world of tax!  With 10,000 local U.S. taxing jurisdictions, fifty states, the IRS, and 195 countries in the world, there are plenty of open palms for your tax dollars.  I’m not sure why people get a glazed look in their eyes when I point this out at cocktail parties.Okay, maybe it isn’t that exciting, but a business plan for a technology start-up, or even an established tech company,...

I Have a (Tax) Plan for That: The Imminent Return of Multistate Tax Planning

The days of naked Delaware holding companies and royalties paid for giraffes named Geoffrey may be long gone but, thanks to the Tax Cuts and Jobs Act of 2017, multistate tax planning is back on the minds of corporate CFOs.  During the 1990s, variations in the tax laws and policies among states imposing corporate income taxes inspired practitioners to present a smorgasbord of plans to restructure multistate organizations with the intent of exploiting these differences...

Public Law 86-272, We Hardly Knew Ye

"Ye're an armless, boneless, chicken-less egg You'll have to be left with a bowl out to beg Oh Johnny I hardly knew ye. . ."  You would know the tune to these lyrics to Oh Johnny I Hardly Knew Ye from its later appropriation for When Johnny Comes Marching Home Again.  In the original 1867 song penned by English music hall notable Joseph B. Geoghegan, the protagonist went off to war. There, he proceeded to lose limbs—arms, legs, and in some versions, even eyes! That...

Think You’re Not a Manufacturing Company? Think Again!

Deadline Approaching for 2018 Retroactive Classification in Massachusetts Like many states, Massachusetts offers significant tax benefits to corporations engaged in manufacturing. But, what is “manufacturing?” In the words of a former U.S. president, “it depends on what the meaning of the word ‘is’ is.” Or, in this case, the meaning of “manufacturing.” The window will soon close for classification as a manufacturing corporation for the 2018 calendar year. Now is the time to consider whether your company...