06 August 2019 State and Local Tax Weekly for July 26 Ernst & Young's State and Local Tax Weekly newsletter for July 26 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. On July 18, 2019, Governor DeWine signed Amended Substitute HB 166, Ohio's fiscal year 2020-21 budget legislation (HB 166). As finalized, HB 166 contains significant tax law changes, including the following:
In addition, HB 166 adopts rules in response to changes necessitated by IRS audits conducted at the entity level and how those entities or investors will pay deficiencies or obtain refunds resulting from IRS adjustments. These provisions apply to IRS adjustments made on or after Oct. 1, 2019.Ohio's provisions are based on the Multistate Tax Commission's "Model Uniform Statute for Reporting Adjustments to Federal Taxable Income and Federal Partnership Audit Adjustments." For a more in-depth discussion of these, and other Ohio tax law changes, included in the Budget Bill, see Tax Alert 2019-1338. Alabama: New law (HB 419) makes significant amendments to Alabama's financial institution excise tax (FIET). Notably, the definition of net income is redefined as federal taxable income (FTI) without federal net operating losses (NOLs), plus required adjustments, as allocated and apportioned under rules issued by the Alabama Department of Revenue (Department). For FIET purposes, Alabama conforms to the Internal Revenue Code on a rolling basis. In computing net income, the items that must be added back to FTI include, among other items: (1) any interest treated as paid or incurred in the current taxable year under IRC §163(j)(2), and (2) deductions for global intangible low-taxed income (GILTI) and foreign-derived intangible income (FDII) under IRC § 250. Items that must be deducted from FTI include, among other items: (1) FDIC insurance premiums not deductible for FTI purposes under IRC § 162(r); (2) interest not deductible for FTI purposes under IRC §163(j)(1); (3) the amount of GILTI included in gross income under IRC §951A; and (4) the amount treated as dividends under IRC §78.2 A deduction for a percentage of dividend income from a captive real estate investment trust is permitted in certain circumstances; the deduction decreases over a five-year period for tax years beginning after Dec. 31, 2019, with no deduction allowed for tax years beginning after Dec. 31, 2024. NOLs under the FIET can be carried forward 15 years (applicable to FIET NOLs incurred in tax years beginning after Dec. 31, 2019). The law repeals NOL carryback provisions. HB 419 also clarifies the order in which FIET NOLs can be deducted, and provides the order in which FIET NOLs incurred by qualified corporate group members must be deducted. Taxpayers electing to file a consolidated return no longer are required to pay a $6,000 fee to do so. Further, an election to file an Alabama consolidated excise tax return is binding on a qualified corporate group for at least 10 tax years, but will automatically terminate upon revocation or termination of the federal consolidated return election. Lastly, starting in 2020, financial institutions are required to make prepaid estimated FIET payments rather than following the post-payment system under prior law. HB 419 takes effect Jan. 1, 2020. Ala. Laws 2019, HB 419, signed by the governor on May 28, 2019. California: The California Franchise Tax Board (FTB) announced in FTB Notice 2019-02 that it is extending the treatment of existing water's-edge elections set forth in FTB Notice 2016-02 and FTB Notice 2017-04 and will not seek to terminate the election of a water's-edge combined reporting group that is unitary with a foreign affiliate that becomes a California taxpayer solely due to the state's bright-line nexus standard3 in a taxable year beginning on or before Dec. 31, 2020. FTB Notice 2019-02 "adheres to and incorporates by reference FTB Notice 2016-02 and FTB Notice 2017-04 in all respects, except the specific date constraints listed as conditions for FTB Notice 2016-02 and FTB Notice 2017-04 to apply." Cal. FTB, FTB Notice 2019-02 (June 26, 2019). Louisiana: The Louisiana Department of Revenue (Department) determined that a taxpayer subject to the federal base erosion anti-abuse tax (BEAT) (which was established by the federal Tax Cuts and Jobs Act (P.L. 115-97)) is not allowed to deduct BEAT under the state's federal income tax paid deduction (La. R.S. 47:287.85). The Department reasoned that the BEAT is not an enumerated item in La. R.S. 47:287.85, and "no explicit exception exists" for the BEAT as compared to the exception for federal alternative minimum tax (AMT) under La. R.S. 47:287.83(B), which allows a deduction for AMT to the extent it applied to regular taxable income. La. Dept. of Rev., Revenue Info. Bulletin 19-010 (July 11, 2019). Maryland: The U.S. Supreme Court (Court) has been asked to review the ruling in Staples, Inc. by the Maryland Court of Special Appeals (Special Appeals Court) (after the taxpayer's petition for review to Maryland's highest court was denied.) The Special Appeals Court ruled that an out-of-state corporation had nexus with Maryland because "enterprise dependency" existed between the out-of-state corporation and its in-state affiliated companies, and that the Comptroller of Treasury did not err by not using the standard apportionment formula applicable to the in-state affiliates to calculate the out-of-state corporation's income attributable to Maryland. Specifically, the question presented by the taxpayer to the Court is: "When an out-of-State business receives royalty fees, franchise fees, or similar payments from in-State businesses, may a State imposing income taxes constitutionally apportion such income to itself based on the activities of only the in-State businesses?" Staples, Inc., et al. v. Maryland Comp. of Treas., No. 2597 (Md. Ct. Special App. Aug. 9, 2018) (unreported), pet. for cert. denied COA-PET-0417–2018 (Md. Ct. of App., Feb. 22, 2019), petition for cert. filed, Dkt. No. 19-119 (U.S. S.Ct. filed July 22, 2019). Montana: In Exxon Mobil Corporation, the Supreme Court of Montana (court) held that a domestic corporation could fully deduct dividends received from its 80/20 subsidiaries. The court observed that determining Montana taxable net income required corporations to first determine their gross income under the Internal Revenue Code (IRC). The corporation is then required by the state tax statute to adjust its federal gross income using specifically enumerated items. The court reaffirmed one of its prior holdings, Baker Bancorporation,4 which allows corporations to claim all available deductions under the IRC unless Montana law expressly provides otherwise. The court addressed the Montana Department of Revenue's (Department) position that the prefatory language in Mont. Code Ann. § 15-31-325 (i.e., "dividends must be treated as follows") evidenced a legislative intent to address all dividends received by a water's-edge group, precluding the corporation from utilizing deductions authorized by IRC § 243. Accordingly, the Department contended, the corporation could only claim an 80% deduction under Mont. Code Ann. § 15-31-325(4). The court rejected the Department's reading of the statute, noting that it would have to "insert what has been omitted" into the framework of the Montana statute. The court noted that Mont. Code Ann. §15-31-325 addresses specific types of dividends apportionable under that section and that only those specifically enumerated dividends are subject to the 80% exclusion. Because Mont. Code Ann. § 15-31-325 did not expressly reference either IRC § 243 or actual dividends received from 80/20 corporations, the court concluded that the legislature did not expressly prohibit other deductions expressly allowed by IRC § 243. As such, the court concluded, the corporation could still claim the deduction authorized under IRC § 243. Since dividends received from a more-than-80%-owned domestic corporation (which would include an 80/20 corporation), would be eligible for a 100% deduction, the corporation could deduct 100% of the dividends received from its 80/20 subsidiaries for Montana corporate income tax purposes. Exxon Mobil Corp. v. Montana Dept. of Rev., 2019 MT 156 (Mont. S.Ct. July 9, 2019). For more on this development, see Tax Alert 2019-1339. New York: On July 3, 2019, the New York State Department of Taxation and Finance (Tax Department) posted for comment revised draft corporate franchise tax regulations under Article 9-A of the New York Tax Law (to be codified at N.Y. Comp. Codes and Regs. tit. 20, Sections 4-2.3 and 4-2.18). The draft regulations address the sourcing of receipts from "sales of digital products" and "other services and other business activities" for receipts factor apportionment purposes.5 The common types of receipts sourced under the "digital products" draft regulation include: receipts from the sale of, rental of, license to use or granting of remote access to digital products and digital services. The common types of receipts sourced under the "other services and other business activities" draft regulation include: income from the sale of intangible property and compensation for certain services (e.g., commissions, finder's fees, loan servicing fees, and fees for professional services). For more on this development, see Tax Alert 2019-1311. Montana: A resort's no-show and cancellation forfeited deposits are not subject to Lodging Facility Use Tax and Sales Tax (collectively "tax"), but the resort services fee charged guests is subject to such taxes. In so holding, the Montana Tax Appeal Board (Board) found that for purposes of the no-show and cancellation fees, no taxable event occurred because potential guests do not "use" the facility for any purpose when they book rooms for lodging and later cancel or do not show up for the reservation. The statutory definition of "accommodation charge" requires actual "use" of the facility, and without this, the Board concluded that no taxable event occurred. The resort services fee, however, is an integral part of the accommodations charge and, thus, is subject to tax. The Board determined that the fee is integral to the lodging facility because guests cannot "use" the facility without paying it. Additionally, the fee is used for infrastructure support, which is not within the type of services listed as excluded from the statutory definition of "accommodations charge." Boyne USA, Inc. v. Mont. Dept. of Rev., No. SPT-2018-24 (Mont. Tax App. Bd. June 11, 2019). New York: In reversing the New York Superior Court, Appellate Division, the New York Court of Appeals (Court) held that a supermarket chain's purchase of competitors' pricing information is a taxable information service that did not qualify for the sales and use tax exclusion under N.Y. Tax Law §1105(c)(1) because the information purchased was not personal and individual in nature. In so holding, the Court reasoned that the New York State Tax Appeals Tribunal made its determination to this effect rationally, and found that competitors' pricing information and the related reports were derived from a non-confidential and widely accessible source (competitors' shelves). Additionally, compiling such information into a customized report for the supermarket chain did not make the information personal or individual in nature. It should be noted that the majority, concurring and dissenting opinions argue over the distinction the Court drew in Matter of Grace,6between tax exclusions and tax exemptions and whether exclusions should be interpreted in favor of the taxpayer (or like an exemption, in favor of the state). In the majority opinion, the Court reaffirmed the conclusion it reached in Matter of Mobil Oil Corp.7 that "[i]n the case of statutory exclusions, the presumption is in favor of the taxing power." The majority of the Court in its opinion further explained that in reaffirming this statement, it is neither stating a new rule under which a taxpayer always loses nor is it overruling its opinion in Matter of Grace, as asserted in the concurring opinion. Matter of Wegmans Food Markets, Inc. v. N.Y. Tax App. Trib., No. 56 (N.Y. June 27, 2019). Texas: New law (SB 1525) clarifies when the sale for resale sales tax exemption can be claimed. The law clarifies that the terms "amusement services" and "personal services" do not include services provided through coin-operated amusement machines that are operated by the consumer. The law modifies the definition of "sale for resale" to clarify when sales of tangible personal property and services to a purchaser for the purposes of transferring the property or service as an integral part of performing a contract with a non-profit organization or with the federal government. Further, a sale for resale does not include the sale of tangible personal property to a purchaser who acquires it to use, consume, expend it in, or incorporate it into an oil or gas well in the performance of an oil well service taxable under miscellaneous occupation taxes. For purposes of the sale for resale for "environment and conservation service" the law makes clear that charges for parts and labor to repair, remodel, maintain, or restore tangible personal property is exempt if: (1) the repair, remodeling, maintenance, or restoration is required by law or regulation in order to protect the environment or to conserve energy; and (2) the charge for labor is separately itemized from the charge for materials furnished. (New requirement italicized.) The exemption does apply to the charge for materials furnished by the service provider to the purchaser as part of the service. Lastly, 65% of a lump-sum charge for such labor and materials is exempted from sales and use tax if the repair, remodeling, maintenance, or restoration legally is required by a governmental or quasi-governmental entity, and the labor and materials are purchased for a health care facility or for an oncology center. These changes took immediate effect. Tex. Laws 2019, SB 1525, signed by the governor on June 10, 2019. Alabama: New law (SB 295) expands and extends Alabama's Apprenticeship Tax Credit Act. For tax years beginning on or after Jan. 1, 2020, eligible employers that employ an apprentice for at least seven full months of the prior taxable year will receive a credit "equal to" $1,250 (previously, "up to" $1,000) for each apprentice employed, for up to 10 (previously five) apprentices employed. The law, however, further requires the Alabama Department of Revenue to work with the other state agencies to "establish a scale reflecting ranges of amounts of money an employer has invested in an eligible apprentice and a corresponding tax credit amount and shall award the tax credit in accordance with this scale … " The credit is not available for an individual apprentice for more than four tax years. An additional tax credit for up to $500 is available for each apprentice who is: (1) under 18 when the credit is claimed; (2) enrolled in a secondary or postsecondary career and technical education program; and (3) participating in certain youth-registered or industry-recognized apprenticeship programs, adult basic literacy programs, or public workforce programs. This additional credit is available for up to 10 apprentices hired. An eligible employer may claim the additional tax credit after employing an in-school youth apprentice for 90 days who meets credit requirements. The cumulative amount of credits that may be awarded cannot exceed $7.5 million (previously $3 million) annually. Additionally, an employer who employs an apprentice for less than the full preceding calendar year, but for at least 210 days during that year, can apply for the full value of the credit (previously, the credit amount was required to be pro-rated monthly). Lastly, the credit's sunset date is extended through 2025 (previously, 2021). SB 295 takes effect Sept. 1, 2019. Ala. Laws 2019, Act 506 (SB 295), signed by the governor on June 10, 2019. Missouri: New law (SB 68) amends workforce development provisions including business incentives for the Missouri Works Program and the new business facility tax credit. The Missouri Works Program is expanded to permit the Missouri Department of Economic Development (Department) to award tax credits to qualified manufacturing companies. Under the program, the qualified manufacturing company must make a manufacturing capital investment of at least $500 million not more than three years after the Department approves a notice of intent and the execution of an agreement. The credits can be issued beginning Jan. 1, 2023, and then may be issued each year for up to five years. A qualified manufacturing company can qualify for another five-year period if it makes an additional manufacturing capital investment of at least $250 million within five years of the Department's approval of the original notice of intent. A single qualified manufacturing company cannot receive more than $5 million in credits in a calendar year, and the aggregate total amount of credits awarded to qualified manufacturing companies cannot exceed $10 million per calendar year. A qualified manufacturing company receiving benefits under the Missouri Works Program cannot simultaneously receive tax credits or exemptions under the Business Use Incentives for Large-Scale Development program for the jobs created/retained or capital improvement that qualified for benefits under the Missouri Works Program. For fiscal years beginning on or after July 1, 2020, an additional $10 million in tax credits may be authorized to complete infrastructure projects directly connected with the retention of jobs under the Missouri Works Program, and an additional $10 million in tax credits may be authorized for each fiscal year for a qualified manufacturing company based on a manufacturing capital investment. Further, the Department can award tax credits in an amount equal to or less than 9% of new payroll, to a qualified company that creates 10 or more new jobs and pays an average wage that equals or exceeds 100% of the county average wage. This provision expires on June 30, 2025. For all fiscal years beginning after July 1, 2020, the maximum total amount of withholding tax that may be retained for the creation of new jobs under the Missouri Works Program by qualified companies with a project facility base employment of at least 50 cannot exceed $75 million for each fiscal year. For purposes of the new or expanded business facility tax credit, the law amends the definition of "new business facility investment" to provide that property may be acquired by the taxpayer by purchase, lease, or license, including the right to use software and hardware through on-demand network access to a shared pool of configurable computing resources if the rights are used at the new business facility. The law also modifies the Missouri Works Job Training Program, renaming it the Missouri One Start Program and adding benefit repayment provisions for qualified companies that fail to maintain new or retained jobs or leave the state within five years of approval of the benefits. Mo. Laws 2019, SB 68, signed by the governor on July 10, 2019. Texas: New law (SB 2) enacts significant property tax reforms related to rates, administration, and certain exemptions. SB 2 lowers the rollback rate from 8% to 2.5% for taxing units that collect more than $15 million in property tax levy and sales tax and requires an automatic rollback election if the taxing unit adopts a tax that exceeds the 2.5% threshold. SB 2 makes various other changes related to rates, including the renaming of certain terms and the creation of an online real-time tax rate notice. Regarding property tax administration, SB 2 requires the Texas Comptroller of Public Accounts (Comptroller) to appoint a property tax administrative advisory board to advise it regarding state administration of property tax and state oversight of appraisal districts. Additionally, the law requires an appraisal district to appraise property according to appraisal manuals prepared and issued by the Comptroller, and requires the Comptroller to prepare the appraisal manual for determining the market value of property based on generally accepted appraisal methods and techniques. Further, effective Sept. 1, 2020, an appraisal review board must establish special panels to conduct protest hearings related to certain commercial property with an appraised value of at least $50 million for the 2020 tax year (inflation-adjusted in subsequent years). Regarding exemptions, the governing body of a taxing unit cannot repeal or reduce the amount of a historic site property exemption that otherwise qualifies for the exemption unless the property owner consents, or the taxing unit provides the owner written notice at least five years before the exemption is repealed or reduced. Additionally, a chief appraiser must accept and approve or deny an application for a freeport goods exemption after the filing deadline if it is filed on or before the later of June 15 or the 60th day after the chief appraiser delivers notice to the property owner. Unless otherwise noted, these changes take effect starting in 2020. Tex. Laws 2019, SB 2, signed by the governor on June 12, 2019. Hawaii: New law (SB 1360 (Act 232)) requires partnerships, estates, and trusts (collectively, "entity") to withhold income tax of nonresident partners and beneficiaries. Tax is to be withheld in an amount equal to the highest marginal tax rate applicable to nonresidents multiplied by the amount of the taxpayer's distributive share of income attributed to Hawaii as reflected in the entity's tax return. This requirement does not apply to publicly traded partnerships; they are required to file an annual information return for each unit holder with Hawaii sourced income. Although the law provides that this requirement applies to tax years beginning after Dec. 31, 2018, the Hawaii Department of Taxation (Department) announced that it "will not require" this withholding while it is preparing to implement and enforce the law. The Department further indicated that " … it intends on requiring withholding under Act 232 no sooner than taxable years beginning after December 31, 2019." Haw. Laws 2019, Act 232 (SB 1360), signed by the governor on July 9, 2019; Haw. Dept. of Taxn., Announcement No. 2019-08 (July 19, 2019). Texas: New law (HB 2256) modifies gas production tax provisions relating to procedures for determining amounts of overpayments and being reimbursed for the overpayment, and allowing the Texas Comptroller of Public Accounts (Comptroller) and a taxpayer to enter into a managed audit of the taxpayer's return. A taxpayer, with approval of the Comptroller, can compute gas production tax overpayments using a sampling of marketing cost transactions, and can be reimbursed for overpayments by either timely filing a refund claim or taking a credit on one or more Producer's Reports or First Purchaser's Reports. Additionally, by written agreement the Comptroller may authorize a taxpayer to conduct a managed audit. The managed audit can be limited to one or more factors that affect a taxpayer's liability, including the gross value of the gas produced, exempt interest, marketing costs of gas produced, gas used to power operations at a well or lease, or tax reimbursement paid by a purchaser to a producer. Generally, a taxpayer is entitled to a refund of any tax overpayment disclosed by a managed audit, but the Comptroller, except in cases of fraud or willful tax evasion, cannot assess a penalty and may waive all or part of the interest that would otherwise accrue on any amount identified to be due in a managed audit. These changes, which take effect Sept. 1, 2019, do not affect tax liabilities accruing before the effective date (prior law applies to these liabilities). Tex. Laws 2019, HB 2256, signed by the governor on June 14, 2019. Maine: Recently enacted Maine LD 369 (Ch. 156) requires that an employer with 10 or more employees in any 120 days in a calendar year must provide paid leave to its employees. According to the governor's news release, the law allows for the use of paid leave for circumstances other than sick pay as long as the employee provides reasonable notice to the employer. Effective Jan. 1, 2021, Maine employers will be required to allow their employees to accrue one hour of paid leave per 40 hours worked, up to a maximum of 40 hours per year. Accrual begins at the start of employment, but the employer is not required to permit use of the accrued leave until the employee has been employed for 120 days during a one-year period. For more on this development, see Tax Alert 2019-1325. New Jersey: The New Jersey Division of Taxation (Division) has issued new guidance on employer reporting requirements in light of the state's adoption of its health insurance mandate, effective for calendar year 2019. In the updated guidance, the Division clarified that employers are obligated to file returns for New Jersey residents. While the state will permit filings for nonresidents if an employer files in bulk, the Division cautions employers that file information about non-New Jersey residents should "consult privacy and other laws pertaining to residents of other [s]tates before sending any sensitive or personal data to New Jersey." The updated guidance does not require employers and other filers to file returns in instances in which the employee is a non-resident but a dependent covered by the employee is a resident. The updated guidance also confirms New Jersey's intent to rely on the federal Forms 1094-C and 1095-C with no state modifications. For more on this development, see Tax Alert 2019-1314. West Virginia: Effective Jan. 1, 2020, the Madison, West Virginia city service fee will increase from $1.25 to $3.00 per calendar week. The Madison city service fee is withheld from the wages of employees who are employed at or physically report to one or more locations within the city and is on the payroll of an employer, on either a full-time or part-time basis. For more on this development, see Tax Alert 2019-1334. San Francisco, CA: On July 17, 2019, San Francisco Board of Supervisors tabled a previously proposed tax on stock-based compensation proposed by Supervisor Mar in May of this year. (See Tax Alert 2019-0973.) The proposal, dubbed the "IPO Tax," was intended to appear on the city's November 2019 ballot. If approved, it would have imposed an additional payroll tax on stock-based compensation to fund affordable housing in the city. The city acknowledged the proposition would have required a supermajority of greater than 66% of voters to pass. The tax will likely be re-introduced to voters as a ballot initiative next year. A ballot initiative would likely require a simple majority of greater than 50% of voters to pass. It is not known whether the ballot initiative will propose applying the tax retroactively. For more on this development, see Tax Alert 2019-1329. Maine: New law (LD 1544) repeals the Maine Uniform Unclaimed Property Act and enacts the Maine Revised Unclaimed Property Act, effective Oct. 1, 2019. Provisions addressed by the new law include: (1) presumed abandonment of various property types (including traveler's checks (15 years), money orders (7 years), state or municipal bonds (3 years), amounts owed on an insurance policy or annuity contract (3 years), safe deposit box contents (3 years), stored-value obligations (3 years), securities (3 years)); (2) rules for taking custody of property presumed abandoned (including priority rules); (3) reports required by holders; (4) notice required to apparent owners of property presumed abandoned; (5) how the administrator takes custody of property (permitting dormancy charges by holders) and sells the property (addressing specific kinds of property such as securities); (6) how property is administered and how to recover property from the administrator; (7) verified reports of property and examination of records requirements; (8) liability determinations and putative holder remedies; and (9) definitions of key terms (among other provisions). LD 1544 does not relieve a holder of a duty that arises before Oct. 1, 2019 to report, pay, or deliver property based on the law in effect for that period. Holders that do not comply with the unclaimed property law in effect prior to Oct. 1, 2019 will be subject to the enforcement and penalties provisions in effect for that time-period. Me. Laws 2019, Ch. 498 (LD 1544), signed by the governor on June 27, 2019. International: On July 18, 2019, amendments to the Kingdom of Saudi Arabia (Saudi Arabia) Value Added Tax (VAT) Implementing Regulations (the Regulations) were published in the Official Gazette. The amendments are effective from the date of publication. For additional information on this development, see Tax Alert 2019-1340. Multistate: A replay of the EY state income tax webcast on July 18, 2019 focusing on the ongoing impacts of the federal Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) on state taxation is now available. The first webcast in this new series discussed how state responses to the TCJA are currently impacting state tax compliance. Topics addressed include state tax compliance considerations for: (1) Global intangible low-taxed income (GILTI), (2) the deductions for GILTI and foreign-derived intangible income (FDII), (3) Section 163(j) limitation on business interest expense, and (4) enduring implications of the Section 965 transition tax. To listen to a replay of this webcast, go to Ongoing impacts of TCJA on state taxation. 2 Language in HB 419 noted that such provisions related to the federal Tax Cuts and Jobs Act (P.L. 115-97) are merely a clarification of existing law and apply retroactively to all open tax years. 3 Cal. Rev. and Tax. Code §23101(b) (effective for taxable years beginning on and after Jan. 1, 2011). 5 While the New York City Department of Finance has not yet issued its own version of these draft regulations, it has indicated on its website that taxpayers may rely on the Tax Department's draft regulations by substituting the City for the State where necessary and disregarding provisions that do not correspond to New York City Admin. Code tit. 11, ch. 6, sub. 3-A. 6 Matter of Grace v. NY State Tax Commn., 37 N.Y. 2nd 193 (1975), rearg. denied 37 N.Y. 2nd 816 (1975). 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. Document ID: 2019-1423 |
