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State & Local Tax news

June 2021

Welcome to the June 2021 Issue of the Aprio 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
General images for resizing purposes (Amit Michaeli) (4)-3


Mobile Workforce Protection Reintroduced in Congress, Enacted in West Virginia and Louisiana

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

As business activity returns to normal, companies whose employees travel for work need to analyze potential state wage withholding obligations against a backdrop of harsh and nonuniform state rules.



California: Taxpayer's Out-of-State Activity Did Not Change Residency Prior to Sale of Stock

By Tina M. Chunn, SALT Senior Manager

When establishing residency in a new state, the actions — or inactions — that you take in your former state are at least as important as the actions you take in your new state, since you will need to prove that you have abandoned the former state as your domicile.



New Indiana Ruling Puts a Spotlight on the Sourcing of Products Sales vs. Services

By Aspen Fairchild, SALT Associate

Determining, whether a business generates revenue from selling tangible property or services, can have a significant impact on the methodology used for sales factor apportionment sourcing.




Allocable vs. Apportionable Income: A New Virginia Tax Ruling Tackles the Topic

By Betsy Goldstein, SALT Manager

When a corporation owns an interest in a partnership, the characterization of income flowing from the partnership, or from the sale of a partnership interest as apportionment business income or allocable nonbusiness income, can have a significant impact on the corporation’s income tax liability.


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.