08 August 2017 State and Local Tax Weekly for July 28 Ernst & Young's State and Local Tax Weekly newsletter for July 28 is now available. Prepared by Ernst & Young's State and Local Taxation group, this weekly update summarizes important news, cases, and other developments in U.S. state and local taxation. Connecticut DRS mails notices to out-of-state online retailers demanding sales records, legislature subsequently enacts penalty provisions for failure to comply The Connecticut Department of Revenue Services (DRS) recently mailed notices to several unregistered online retailers demanding electronic sales records for all individual sales made to customers with Connecticut addresses over the past three years. In lieu of providing sales records, the DRS offers the option of voluntarily registering for Connecticut sales and use tax purposes and prospectively collecting and remitting tax on sales to Connecticut customers. While the notices require the recipient to respond within a specific deadline, they do not address potential penalties or other consequences of failing to respond. On July 7, 2017, however, Governor Dannel Malloy signed Public Act No. 17-147 into law, which gives the Commissioner authority to impose a civil penalty of $500 per violation for failing to comply with these type of information requests, effective July 1, 2017. In light of the new potential penalties associated with failure to comply, companies should consider their procedural options, including the following: — Consider providing the state with basic sales records, with customer names and addresses redacted if the company has concerns around disclosing customer-specific information. While this should satisfy the DRS's initial information request, companies should anticipate receiving a follow-up notice requesting that they "voluntarily" register due to having more than 100 transactions delivered to Connecticut destinations. Further, this may put the company at risk that the DRS will assert economic nexus for the past three years (or more) — assuming that there have been 100 transactions in each of those years. It is unknown at present how the DRS will respond to companies that refuse to further comply with its requests. — Voluntarily register for prospective compliance. Before contacting the DRS, however, we recommend companies first consult with a tax advisor to discuss procedural options regarding potential liability for past periods and allow proper lead time to ensure systems are in place to properly collect Connecticut use tax from customers. For additional information on this development, see Tax Alert 2017-1203. The first two quarters of 2017 were very busy in Illinois, both at the state and local level, culminating on July 6, 2017, with a last minute deal (approved over the Governor's veto) that narrowly avoided a third straight year without a state budget. Tax changes included in the budget bill are codified in Public Act 100-0022 (which was SB 9 as it went through the legislative process). Among the changes is a permanent increase to both the individual and corporate tax rates of 33%, modification of Illinois' combined reporting provisions to repeal the like-apportionment rule, decoupling Illinois from the IRC §199 production deduction, reinstatement of the state's research and development (R&D) credit through 2021, exempting from sales and use tax graphic arts machinery and equipment used in manufacturing, and amending many of the state's unclaimed property rules through the adoption of the Revised Uniform Unclaimed Property Act. In addition to the tax law changes contained in the Public Act, other tax law changes are set forth in still other tax legislation pending Governor Rauner's signature. Finally, of note at the local level, Cook County joined the chorus of localities around the US enacting a sweetened beverage tax while the City of Chicago enacted a checkout bag tax. Tax Alert 2017-1227 provides a summary of the most significant of these many changes. See Tax Alert 2017-1228 for an in-depth discussion of how the combined reporting changes affect insurance groups. Federal: In Notice 2017-36, the IRS delayed application of the documentation regulations under the Section 385 regulations (T.D. 9790) by 12 months. "In response to the concern that taxpayers have continued to raise with the application of the [documentation regulations] to interests issued on or after Jan. 1, 2018, and in light of further actions concerning the final and temporary regulations under [Section] 385 in connection with the review of those regulations, the Treasury Department and the IRS have determined that these concerns warrant a delay in the application of the [documentation regulations] by 12 months," the Notice stated. "Accordingly, the Treasury Department and the IRS intend to amend the [documentation regulations] to apply only to interests issued or deemed issued on or after Jan. 1, 2019." The Notice also requested comments by Friday, Sept. 1, 2017, concerning whether the proposed amendment and delay afford adequate time for taxpayers to develop any necessary systems or processes to comply with the documentation regulations. The so-called funding requirements have not been delayed, however. For additional information on this development, see Tax Alert 2017-1241. Connecticut: New law (HB 7312) modifies various income tax related provisions. Effective for taxable years beginning on or after Jan. 1, 2017, an individual is required to include in Connecticut adjusted gross income , to the extent not properly includable in federal gross income, an amount equal to any compensation required to be recognized under IRC §457A (nonqualified deferred compensation from certain tax indifferent parties) attributable to services performed in Connecticut. In addition, and effective upon passage, HB 7312: (1) clarifies ownership requirements for sourcing income from certain Connecticut real property, specifying that the pass-through entity (i.e., partnership, LLC, S corp.) may own the property directly or indirectly; and (2) excludes any voting power, beneficial interests, or shares in a real estate investment trust (REIT) that are directly owned or controlled by a segregated asset account of a life insurance company (as described in IRC §817, Treatment of variable contracts) in determining whether a REIT is a captive REIT. Conn. Laws 2017, Pub. Act No. 17-147 (HB 7312), signed by the governor on July 7, 2017. Hawaii: New law (HB 209) increases the individual income tax rates on high wage earners, beginning with the 2018 tax year. The current highest rate of 8.25% applies to income over $96,000 for joint filers, $48,000 for single filers, and $72,000 for head of household filers. For joint filers, the new rates are: 8% for income over $96,000 but not over $300,000; 9% for income over $300,000 but not over $350,000; 10% for income over $350,000 but not over $400,000; and 11% for income over $400,000. For single filers, the new rates are: 8% for income over $48,000 but not over $150,000; 9% for income over $150,000 but not over $175,000; 10% for income over $175,000 but not over $200,000; and 11% for income over $200,000. For head of household filers, the new rates are: 8% for income over $72,000 but not over $225,000; 9% for income over $225,000 but not over $262,500; 10% for income over $262,500 but not over $300,000; and 11% for income over $300,000. Haw. Laws 2017, Act 107 (HB 209), signed by the governor on July 10, 2017. Tennessee: An out-of-state over-the-road, for-hire trucking company that does not own or rent property in Tennessee or have employees or shareholders in the state has substantial nexus with the state for franchise and excise tax purposes due to its in-state activities. The Tennessee Department of Revenue (Department) explained that these activities include providing intrastate transportation services within Tennessee, delivering goods into Tennessee that originate in another state, and transporting goods from Tennessee for delivery into another state. Traveling through Tennessee on one or more trips that originate and terminate outside Tennessee, where the vehicle makes no pickups or deliveries and conducts no other business activity in Tennessee does not constitute doing business in Tennessee. Thus, if the trucking company makes trips that both begin and end in Tennessee, delivers goods into Tennessee that originate in another state, or makes pickups of goods from Tennessee for delivery into another state during its tax year, it is subject to Tennessee franchise and excise taxes. The Department noted that nexus also can be created if the bright-line presence nexus standard is met (i.e., $50,000 of property or payroll, $500,000 of receipts, or 25% of its total payroll, property or receipts in Tennessee). Non-nexus creating activities include driving through the state without making any pickups or deliveries, or stopping in the state for fuel or meals. In addition, the following special apportionment formula applies to common carrier motor carriers that are subject to franchise and excise taxes: (A) gross receipts from intrastate operations divided by gross receipts from operations everywhere, plus (B) in-state odometer miles divided by everywhere odometer miles; (C) divided by two. Tenn. Dept. of Rev., Rev. Ruling No. 17-08 (June 21, 2017). Connecticut: New law (HB 7312) provides that, effective Oct. 1, 2017, sales and use tax permits will expire every two years unless otherwise specified. Permits issued before then expire every five years. In addition, effective Jan. 1, 2018, HB 7312 codifies Connecticut's requirement to remit sales tax on an annual basis for parties whose total tax liability for the 12-month period ending on the previous June 30 was less than $1,000. Conn. Laws 2017, Pub. Act No. 17-147 (HB 7312), signed by the governor on July 7, 2017. Cook County, IL: On July 28, 2017, the Cook County Circuit Court (court) dismissed a lawsuit1 filed by the Illinois Retail Merchants Association challenging the constitutionality of the Cook County, IL (County) Sweetened Beverage Tax, which was slated go into effect July 1, 2017. The court also dissolved the order it had issued temporarily enjoining the collection of the tax. While the injunction was in place, retailers were instructed by the County to refrain from collecting the tax from their customers until the court issued its final ruling. Retailers also were advised not to file the floor tax return, which was initially due on July 1, 2017. Following, the case's dismissal, the County posted guidance on its website advising distributors and retailers to collect the tax beginning Aug. 2, 2017, and to take inventory beginning Aug. 1, 2017, for purposes of determining the floor tax. For additional information on this development, see Tax Alert 2017-1248. Missouri: New law (SB 16) exempts from sales and use tax usual and customary delivery charges that are separately stated from the sales price. This change takes effect Aug. 28, 2017. Mo. Laws 2017, SB 16, signed by the governor on July 5, 2017. Missouri: New law (SB 49) continues to prohibit the Missouri Department of Revenue from sending notice to any taxpayer regarding taxability of transactions under IBM2 until Aug. 28, 2018 (from Aug. 28, 2017). In IBM, the Missouri Supreme Court found that the taxpayer was not entitled to a use tax exemption for hardware and software sold to a large credit card company because the credit card company's use of the materials for processing credit and debit card transactions did not qualify as "manufacturing of any product" under the statute. In addition, SB 49 limits the combined county and city sales tax rates counties and cities can submit for voter approval. SB 49 takes effect Aug. 28, 2017. Mo. Laws 2017, SB 49, signed by the governor on July 10, 2017. Tennessee: A lump-sum price charged by a business to engineer, procure, and construct a fiber-to-the-home network infrastructure for a high speed internet provider (client) is subject to sales and use tax because the business sells and installs tangible personal property that remains tangible personal property after installation. Under Tennessee law, the sale and installation of materials is subject to sales and use tax if the materials remain tangible personal property following installation, but are exempt from tax if they become affixed to realty upon installation. Here, the Tennessee Department of Revenue (Department) determined the client's legal right to remove the materials installed by the business showed a clear intent for the client to retain ownership of the materials such that they remain personalty after installation. Based on the reasoning in ANR Pipeline Co.3 and American Fiber Systems, Inc.,4 the Department found the materials do not become affixed to the real property upon installation and remain tangible personal property that the client owns. Tenn. Dept. of Rev., Rev. Ruling No. 17-09 (June 21, 2017). Texas: An out-of-state company's charges for provision of a cloud-based software platform that allows subscribing businesses to manage customer communications and use data and analytics functions through a dashboard application are subject to sales and use tax because the company is engaged in taxable data processing service. The Texas Comptroller of Public Accounts found that the company engages in data processing services by storing customers' messages and related information for subsequent retrieval, translating incoming messages into an accessible format, and creating analytic reports for subscribers' uses. Further, the dashboard service is software as a service (SaaS), which is a taxable data processing service. It should be noted that the first 20% of data processing service charges are exempt from sales and use tax under Texas law. Lastly, the provider's separately stated charge for the rental of specialized printers is subject to sales and use tax as the rental of tangible personal property. Tex. Comp. of Pub. Accts., No. 201705045L (May 30, 2017). Hawaii: New law (SB 100) requires the Hawaii Department of Taxation to provide auditors with any tax records necessary to conduct reviews of certain credits, exclusions, deductions, or exemptions from income tax, financial institutions tax, general excise and use taxes, public service company tax, and insurance premium tax. The auditor must not disclose information marked confidential, unless the auditor deems such disclosure necessary and relevant for legislative review purposes. Confidential information that is disclosed cannot contain information that explicitly identifies any specific taxpayer or beneficiary of the exemption, exclusion, credit, or deduction. Further, the legislature must keep such information confidential. SB 100 also clarifies the review criteria regarding the achievement of the legislative purpose of the exemption, exclusion, credit, or deduction, and delays the review schedule of each by one year. SB 100 took effect immediately. Haw. Laws 2017, Act 177 (SB 100), signed by the governor on July 11, 2017. Hawaii: New law (HB 591) modifies provisions related to the Hawaii capital infrastructure tax credit. The bill amends the definition of "capital infrastructure costs" to include capital expenditures for structures, machinery, equipment, or capital assets that are paid or incurred in connection with the displaced tenant's move to a new location within Honolulu Harbor, provided that the capital infrastructure costs do not include amounts for which another credit is claimed or any amounts received from the state. The credit is equal to 50% of the capital infrastructure costs paid or incurred by the qualified infrastructure tenant during the taxable year, up to a maximum of $2.5 million per qualified infrastructure tenant per taxable year. HB 591 permits capital infrastructure costs that exceed $2.5 million in any taxable year to be carried over to later tax years until exhausted, for generation of the credit, provided that: (1) a qualified infrastructure tenant may form a special purpose entity to raise investor capital and claim the credit on behalf of the qualified infrastructure tenant; (2) the qualified infrastructure tenant, together with all of its special purpose entities, including all partners and members of the qualified infrastructure tenant and its special purpose entities, cannot claim any credit in any one taxable year that exceeds $2.5 million; and (3) the credit cannot be claimed after Dec. 31, 2019. HB 591 also includes a penalty for failure to timely submit required information. These changes took immediate effect. Haw. Laws 2017, Act 213 (HB 591), became law without the governor's signature on July 12, 2017. Missouri: New law (HB 93), for purposes of the Missouri works training program, amends the definition of "new capital investment" to allow costs incurred before acceptance of the proposal for benefits by a qualified company at the project facility to be considered new capital investment. Previously, to qualify as a new capital investment, costs had to be incurred after acceptance by the qualified company of the proposal for benefits from the Missouri Department of Economic Development or the approval of the notice of intent, whichever occurred first. In addition, the bill authorizes the state to provide assistance through the Missouri Works Jobs Development Fund to a consortium of a majority of qualified companies organized to provide common training to the consortium members' employees. These changes take effect Aug. 28, 2017. Mo. Laws 2017, HB 93, signed by the governor on July 5, 2017. Pennsylvania: New law (Philadelphia Bill No. 170515) enacted by the Philadelphia city council extends the benefits of Keystone Opportunity Zones, Economic Development Districts, and Strategic Development Areas (e.g., exemptions, abatements or credits from certain taxes) to specific parcels in Philadelphia. The expansion takes effect on the earlier of: (1) the date the parcel is occupied by a qualified business; and (2) the date on which any existing benefits expire with respect to such parcel; or any other date designated by the Commonwealth Department of Community and Economic Development (DCED). The benefits expire 10 years after they begin. The DCED, however, will determine when a sales and use tax exemption takes effect. These changes take effect upon approval by the DCED of an application for the expansion and extension of certain zones and subzone and only with respect to such expansion and extension and for the period of time provided by the Commonwealth for exemptions, abatements or credits. Philadelphia, Pa. Laws 2017, Bill No. 170515, signed by the mayor on June 21, 2017. New Hampshire: New law (HB 316) establishes a statewide property tax exemption for local option commercial and/or industrial construction that any city or town (i.e., eligible municipality) in the state may vote to adopt. The exemption takes effect in the tax year beginning April 1 following its adoption. The exemption only applies to municipal and local school property taxes assessed by the municipality, and excludes state education property taxes and county taxes assessed against the municipality. The exemption is a specified percentage on an annualized basis of the increase in assessed value attributable to construction of new structures, and additions, renovations, or improvements to existing structures, but cannot exceed 50% per year. The exemption can run for up to 10 years following the new construction. Once a municipality adopts the exemption, the percentage rate and its duration must be granted uniformly to all projects for which a proper application is filed. HB 316 describes the procedures required to adopt the exemption and to apply for the exemption. HB 316 takes effect Aug. 28, 2017. NH Laws 2017, Ch. 179 (HB 316), signed by the governor on June 29, 2017. Texas: New law (HB 3103) clarifies Texas's jurisdiction to tax tangible personal property related to trucking companies that operate tractors and trailers throughout the United States. Under the law, Texas has jurisdiction to tax tangible personal property if the property is used continually in the state, whether regularly or irregularly. HB 3103 clarifies that property is considered to be used continually, whether regularly or irregularly, in Texas if the property is used in Texas three or more times on regular routes or for three or more completed assignments occurring in close succession throughout the year. A series of events are considered to occur in close succession throughout the year if they occur in sequence within a short period of intervals from the beginning to the end of the year. HB 3103 took immediate effect. Tex. Laws 2017, HB 3103, signed by the governor on June 15, 2017. Connecticut: New law (HB 7312) extends the due date of the corporation business tax return, applicable to taxable years beginning on or after Jan. 1, 2017. As revised, the corporation business tax return is due on or before the 15th day (previously, the first day) of the month next succeeding the due date of the company's corresponding federal income tax return for the income year, determined without regard to any extension of time for filing. The corporation business tax return for a company not required to file a federal income tax return is due on or before the 15th day of the fifth month (previously, fourth month) next succeeding the end of the income year. The deadlines for information returns and installment payments on estimated tax are also amended. Conn. Laws 2017, Pub. Act No. 17-147 (HB 7312), signed by the governor on July 7, 2017. Tennessee: The Tennessee Department of Revenue (Department) issued guidance on making quarterly estimated tax payments under the new alternative annualized income tax method enacted under Pub. Ch. 194 (2017). Effective for tax years beginning on or after Jan. 1, 2017, taxpayers may elect to calculate estimated tax installments by using an annualized income method, which usually results in quarterly installments that differ from quarter to quarter. Under the annualized income method, franchise and excise components are calculated separately. The excise tax component of each installment is calculated as provided in IRC §6655(e)(2) (failure by corporation to pay estimated tax). Each installment of the franchise tax component is calculated in the following way: the lesser of 25% of the franchise tax shown on the tax return for the preceding tax year (annualized if less than 12 months) or 25% of 80% of the current year's tax liability. This election can be made annually on the franchise, excise tax return forms FAE 170 or FAE 174; all quarterly installments must be determined using the same method. The Department provides a worksheet for calculating quarterly estimates under both the standard method and the annualized income method on its website. Tenn. Dept. of Rev., Notice No. 17-15 (July 2017). Connecticut: New law (HB 7312) changes the order in which partial tax payments must be applied to tax liabilities. Under current law, partial tax payments are applied first to penalties, then interest, and then tax due. Effective July 1, 2018, payment must first be applied to satisfy penalties, then tax due, and then interest. In addition, as of July 1, 2017, penalty waiver requests received more than one year after the notice date will no longer be considered. Lastly, effective July 1, 2017, the Commissioner has the authority to impose a civil penalty of $500 per violation on taxpayers that fail to comply with the Commissioner's request for sales tax information under Conn. Gen. Stat. §12-426(4) and (5). Conn. Laws 2017, Pub. Act No. 17-147 (HB 7312), signed by the governor on July 7, 2017. Delaware: New law (HB 66) codifies the requirement that employers file Forms W-2 reporting employee compensation and Forms 1099-MISC reporting nonemployee compensation with the Delaware Division of Revenue by the IRS deadline of January 31. The change is effective for returns filed after Dec. 31, 2017. The Division had already administratively changed the Form W-2 deadline from February 28 (March 31 for electronically filed returns) to January 31 effective with the filing of the 2016 Forms W-2, due Jan. 31, 2017. For additional information on this development, see Tax Alert 2017-1206. Nevada: Governor Brian Sandoval recently vetoed SB 196 which would have required employers of 25 or more employees to provide paid sick leave to their full-time employees. The requirement would have been effective Jan. 1, 2018. For more on this development, see Tax Alert 2017-1207. Ohio: An out-of-state agricultural commodities trader's (trader) gross receipts from forward contracts through which the trader sold commodities to customers who ultimately received tangible personal property in Ohio were properly sitused to Ohio for Commercial Activity Tax (CAT) purposes. In reaching this conclusion, the Ohio Board of Tax Appeals (BTA) found that while the forward contracts in which the trader engaged arguably have some characteristics of financial instruments, the trader takes title to commodities to provide them to consumers, and recognizes revenue when title is transferred upon shipment of such commodities to customers. Because the trader failed to establish that its gross receipts are from the sale of financial instruments, it could not situs the gross receipts under the situsing statute applicable to dividends, interest, and other sources of income from certain financial instruments, which would have resulted in zero receipts being sourced to Ohio. In addition, the BTA found the Commissioner did not err in taxing the trader's forward contracts without netting them against the trader's futures contracts. By only including gross receipts from the forward contracts, and not the futures contracts, in the assessment, the trader's hedging transactions were properly excluded from the calculation of taxable gross receipts. Central State Enterprises, LLC v. Testa, No. 2016-380 (Ohio Bd. Tax App. July 5, 2017). Oregon: New law (HB 2391) imposes an additional 0.7% assessment on net revenue on each hospital in Oregon that is not a Type A hospital or a Type B hospital. A lower rate of assessment may be imposed on Type A and Type B hospitals. In addition, the definition of "hospital" is amended to exclude hospitals that provide only psychiatric care, pediatric specialty hospitals that provide care to children at no charge, and public hospitals other than hospitals created by certain health districts. HB 2391 also requires the Public Employees' Benefit Board (PEBB) and managed care organizations (MCO) to pay an assessment of 1.5% of the gross amount of premium equivalents received during any calendar quarter, applicable to premium equivalents beginning on or after Jan. 1, 2018 through Dec. 31, 2019. In addition, insurers are subject to an assessment of 1.5% on the gross amount of premiums earned by the insurer during the calendar quarter that were derived from health benefit plans delivered or issued for delivery in Oregon. The assessment applies for a period of eight calendar quarters beginning on the date, on or after Jan. 1, 2018, that the policy or certificate for which the premiums are paid is issued or renewed. Insurers can increase their premium rate on policies or certificates that are subject to the assessment by 1.5%. Failure of the PEBB, MCO or insurer to file a verified form or pay a required assessment will result in a penalty of up to $500 per day of delinquency, capped at 5% of the assessment due for that calendar quarter. Unless otherwise provided, these changes take effect on the 91st day after the legislature adjourns sine die. Ore. Laws 2017, Ch. 538 (HB 2391), signed by the governor on July 3, 2017. Washington: The Washington Department of Revenue (Department) issued interim guidance on attributing receipts earned from providing internet advertising services for business and occupation (B&O) tax purposes. Advertising service providers' receipts are attributed to the location(s) where the customer conducts its selling activity (i.e., where it delivers products or services to purchasers). If specific information about where a customer's related business activity occurs is available to an advertising service provider, that information must be used for receipt attribution purposes. Without specific information, advertising service providers can use a reasonable proportional method that is "uniform, consistent, and accurately reflects the market, and does not distort the taxpayer's market." Internet access statistics from the Federal Communications Commission (FCC) can be used to proportionally attribute receipts from national internet advertising services, provided this method is not distortive. FCC data, however, should not be used when attributing receipts from advertising services targeting a specific region. The guidance provides an example of a reasonable proportional method for attributing receipts from regional advertising services. If an internet advertising service provider using the reasonable proportional method acquires specific information allowing it to more accurately attribute internet advertising receipts, it must use the specific information available. The interim guidance provides examples; it does not address attribution of receipts from international advertising services. Wash. Dept. of Rev., Tax Topic: Interim Statement Regarding the Attribution of Internet Advertising Receipts (June 22, 2017). Washington: The Washington Department of Revenue (Department) issued interim guidance to explain how to attribute receipts from providing research and development (R&D) services for business and occupation (B&O) tax purposes. Receipts from R&D services concerning an existing, available product should be proportionally attributed to the locations that comprise the product's established market. Otherwise, where the R&D work relates to a new product in development, the service provider should attribute the receipts to the location where the customer uses the services in developing the product. Generally, the Department takes the position that a taxpayer provides R&D services for a customer only if the taxpayer is responsible for achieving specific R&D work product deliverables. R&D services relate to specific and identifiable tangible personal property (TPP) if the taxpayer: (1) provides its services with respect to existing TPP; or (2) designs new TPP that is specific/unique (i.e., not intended for mass production). These receipts should be attributed to the locations where the TPP is located or intended or expected to be located. If a taxpayer performs R&D services for a specific product with an existing product market, the taxpayer's service relates to its customer's selling activity or its customer service activity, and would be attributed to the locations where the product is sold or used. If the services do not relate to an existing product, the taxpayer's service cannot relate to the customer's selling activity, and the most closely related customer business activity is likely the customer's own R&D activity or a manufacturing activity. The tax topic provides examples. Wash. Dept. of Rev., Tax Topic: Interim Statement Regarding the Attribution of Receipts from R&D Services (June 22, 2017). International: The Cyprus Tax Department (CTD) recently announced the end of its previous practice of refunding value-added tax (VAT) using checks and will transition solely to issuing VAT refund payments to the bank accounts of the respective businesses. Businesses will need to complete a designated form for the handling of VAT refund requests already submitted as well as future submissions. The CTD has also recently reached an agreement with commercial banks for outstanding VAT payments to be made through their e-banking platforms. For additional information on this development, see Tax Alert 2017-1222. Because the matters covered herein are complicated, State and Local Tax Weekly should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor. 1 Illinois Retail Merchants Ass'n et al v. Cook Cnty. Dept. of Rev., No. 17 L 50596 (Cir. Ct. of Cook Cnty., Ill. July 28, 2017). 3 ANR Pipeline Co., et al. v. Tenn. Bd. of Equal., Nos. M2001-01098-COA-R12-CV, M2001-01117-COA-R12-CV, M2001-01119-COA-R12-CV (Tenn. Ct. App. Dec. 19, 2002), perm. app. denied, June 30, 2003. Document ID: 2017-1287 |
