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State & Local Tax news

March 2021

Welcome to the March 2021 Issue of the Aprio State & Local Tax (SALT) Newsletter

Welcome to the March 2021 edition of Aprio’s State & Local Tax (SALT) newsletter. This issue of the newsletter contains articles addressing:

In case you missed prior issues of this newsletter, please click here.

If you have any comments or questions regarding current or future topics, or if you would like to learn more about Aprio's SALT Practice, please email me at

Jeff Glickman
Jeff Glickman, J.D., LL.M.
Partner-in-Charge, State & Local Tax Practice


Have a Vacation Home in New York? Double-Check Your Tax Liability

By Jess Johannesen, SALT Senior Manager

Some states treat taxpayers as residents if they are in the state for more than 183 days and maintain a “permanent place of abode.” This New York decision illustrates that your vacation home could qualify as a permanent place of abode.



Amended Texas Franchise Tax Apportionment Regulation Adopts Significant Sourcing Changes

By Jeff Glickman, J.D., LL.M, SALT Partner-in-Charge

Texas recently adopted major revisions to its franchise tax receipts factor sourcing apportionment regulation, many of which may have retroactive application. Businesses should understand how these amendments will impact their Texas franchise tax liability.



How the Products You Sell Impact Your Purchase Exemptions

By Tina M. Chunn, SALT Senior Manager

Two recent New York sales tax advisory opinions highlight the relationship between the characterization of a business’s sales to customers and its ability to claim certain exemptions on its purchases.




To Tax or Not to Tax? Using the True Object Test to Assess Sales Taxability

By Betsy Tuck, SALT Manager

For sales tax purposes, when classifying a transaction as taxable software or a nontaxable service, states will often apply the “true object” test, and if the software is merely incidental and of no value without the underlying service, the state may view the entire transaction as a nontaxable service.


About Aprio's State and Local Tax Practice

Aprio's SALT Practice advises clients on the state and local tax implications of their business operations, allowing clients to strategically minimize their liabilities and risks. Our team has over 50 years of combined SALT experience working in industry, state departments of revenue, public accounting and private law practice. We specialize in all areas of SALT, including matters related to state tax nexus, corporate and personal income taxes, sales/use tax, franchise/net worth taxes, credits and incentives, and mergers and acquisitions. In addition, we represent clients in administrative matters before state revenue departments around the country, including audit defense and settlement negotiations, pursuing voluntary disclosure agreements and obtaining letter rulings.