Home - Blank Rome LLP

Register to receive insights and analyses on breaking news and trends across varying industries.
<a class="link-primary mt-4" href="/subscribe">Subscribe</a>

Philadelphia, PA

New York, NY

Wilmington, DE

Cincinnati, OH

Princeton, NJ

Los Angeles, CA

Houston, TX

Tampa, FL

Shanghai

South Florida

Pittsburgh, PA

Washington, D.C.

Chicago, IL

Orange County, CA

Dallas, TX

Boston, MA

Welcome to the August 2025 edition of&nbsp;The BR State + Local Tax Spotlight. We know the importance of remaining up-to-date on State + Local Tax developments, which appear often and across numerous jurisdictions. Staying informed on significant developments and decisions helps tax departments function more efficiently, along with improving strategy as well as planning. That is where&nbsp;The BR State + Local Tax Spotlight&nbsp;can help. In each edition, we will highlight important State + Local Tax developments that could impact your business. In this issue, we will be covering:&nbsp;

core/paragraph

Internet Tax Freedom Act Preempts New York’s Imposition of Tax

core/list-item

California Office of Tax Appeals Denies Occasional Sale Exemption from Sales Tax to Dental Practice

Appellate Court Upholds “Drop Shipment” Sourcing Regulation Under Washington B&amp;O Tax

core/list

We invite you to share&nbsp;The BR State + Local Tax Spotlight&nbsp;with your colleagues and visit Blank Rome’s State + Local Tax&nbsp;<a href="https://www.blankrome.com/services/tax/state-local-tax">webpage</a>&nbsp;for more information about our&nbsp;<a href="https://www.blankrome.com/services/tax/state-local-tax#team">team</a>. Click&nbsp;<a href="https://communications.blankrome.com/10/1143/landing-pages/preference-manager.asp?sid=blankform">here</a>&nbsp;to add State + Local Tax to your subscription preferences.

Updates from previous editions.

In the&nbsp;<a href="https://www.blankrome.com/publications/br-state-local-tax-spotlight-july-2024">July 2024</a>&nbsp;edition of&nbsp;The BR State + Local Spotlight, Nicole L. Johnson authored an article titled “To Be or Not To Be A Unitary Business” in which she discussed the Michigan Court of Appeal’s decision in&nbsp;Nationwide Agribusiness Insurance Company v. Dep’t of Treasury. The Michigan Department of Treasury requested the Michigan Supreme Court reverse the lower court’s decision. On August 6, 2025, the Council on State Taxation filed an amicus brief urging the Michigan Supreme Court to affirm the lower court’s decision.

In the&nbsp;<a href="https://www.blankrome.com/publications/br-state-local-tax-spotlight-january-2024">January 2024</a>&nbsp;edition of&nbsp;The BR State + Local Spotlight, Kara M. Kraman authored an article titled “New York State Tax Appeals Tribunal Denies Resident Credit for Tax Paid to Connecticut on Carried Interest” in which she discussed the New York State Tax Appeals Tribunal’s decision in&nbsp;Matter of Greenberg. Greenberg appealed the tribunal’s decision to the New York Supreme Court Appellate Division, Third Department. In a notice filed with the court on July 31, 2025, the taxpayer withdrew and discontinued her appeal.&nbsp;

<a href="/people/joshua-m-sivin/" id="18870">Joshua M. Sivin</a>&nbsp;and&nbsp;<a href="/people/melanie-l-lee/" id="18827">Melanie L. Lee</a>

core/separator

core/heading

Internet Tax Freedom Act Preempts New York’s Imposition of Tax

By&nbsp;<a href="/people/craig-b-fields/" id="18985">Craig B. Fields</a>

The New York State Tax Appeals Tribunal, affirming an Administrative Law Judge, held that the Internet Tax Freedom Act prohibits the Division of Taxation from subjecting to tax the receipts that Verizon New York, Inc. receives from its sales of internet access. <a href="/news-and-events/internet-tax-freedom-act-preempts-new-yorks-imposition-tax/" id="25857">Read More &gt;&gt;</a>

California Office of Tax Appeals Denies Occasional Sale Exemption from Sales Tax to Dental Practice

By&nbsp;<a href="/people/joshua-m-sivin/" id="18870">Joshua M. Sivin</a>

In a recently released, nonprecedential decision, the California Office of Tax Appeals upheld a sales tax assessment of nearly $1 million against an owner/operator of dental practices, finding that the sale of the taxpayer’s dental practices and associated business assets did not fall within the occasional sale exemption from sales tax. <a href="/news-and-events/california-office-tax-appeals-denies-occasional-sale-exemption-sales-tax-dental/" id="25856">Read More &gt;&gt;</a>

That’s What I Said, Not What I Meant

By&nbsp;<a href="/people/nicole-l-johnson/" id="18986">Nicole L. Johnson</a>

It is estimated that over 80 percent of tax cases settle before a hearing is held. <a href="/news-and-events/thats-what-i-said-not-what-i-meant/" id="25855">Read More &gt;&gt;</a>

Appellate Court Upholds “Drop Shipment” Sourcing Regulation Under Washington B&amp;O Tax

By&nbsp;<a href="/people/irwin-m-slomka/" id="18982">Irwin M. Slomka</a>

The interpretation of the term “purchaser” under the Washington State Business and Occupation tax statute was the determining factor in a Washington Court of Appeals decision upholding a State Department of Revenue regulation that sourced “drop shipments” to Washington even though the taxpayer wholesaler’s own customers were not located in the State. <a href="/news-and-events/appellate-court-upholds-drop-shipment-sourcing-regulation-under-washington-bo-tax/" id="25854">Read More &gt;&gt;</a>

WHAT'S SHAKING: BLANK ROME'S STATE + LOCAL TAX ROUNDUP

Blank Rome’s nationally prominent State + Local Tax attorneys are thought leaders in the community as frequent guest speakers at various local and national conferences throughout the year. Our State + Local Tax attorneys believe it is necessary to educate and inform their clients and contacts about topics that will impact their businesses. We invite you to attend, listen, and learn as our State + Local Tax attorneys interpret and discuss key legal issues companies are facing and how you can put together a plan of action to mitigate risk and advance your business in accordance with state and local tax laws. <a href="/news-and-events/whats-shaking-blank-rome-state-local-tax-roundup/" id="25939">Read More »</a>

core/button

core/buttons

© 2025 Blank Rome LLP. All rights reserved. Please contact Blank Rome for permission to reprint. Notice: The purpose of this update is to identify select developments that may be of interest to readers. The information contained herein is abridged and summarized from various sources, the accuracy and completeness of which cannot be assured. This update should not be construed as legal advice or opinion, and is not a substitute for the advice of counsel.

The BR State + Local Tax Spotlight: August 2025

Offices

Stay Connected

Slide Menu

Slide Search

The BR State + Local Tax Spotlight: August 2025

Offices

Stay Connected