Warm holiday wishes! As winter settles in, we hope you have enjoyed each edition of The BR State + Local Tax Spotlight this year. Wishing you and your loved ones a joyful holiday season and a prosperous new year ahead.
Welcome to the December 2025 edition of 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 The BR State + Local Tax Spotlight 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:
- Taxpayer Fails to Overcome California Assessment Based on Federal Change
- California Broadly Interprets “Doing Business” for LLC Tax, Finding Nexus Thresholds Are Not a Safe Harbor
- Alabama Tax Tribunal Interprets Statute of Limitations Ambiguity to Avoid Having Purchaser’s Refund Claims Time-Barred
- Sibling Rivalry: Florida v. California
We invite you to share The BR State + Local Tax Spotlight with your colleagues and visit Blank Rome’s State + Local Tax webpage for more information about our team. Click here to add State + Local Tax to your subscription preferences.
ARTICLES
Taxpayer Fails to Overcome California Assessment Based on Federal Change
The California Office of Tax Appeals sustained the majority of a proposed assessment resulting from a federal change as the taxpayer did not provide sufficient evidence to overcome the assertion of additional tax. Read More >>
California Broadly Interprets “Doing Business” for LLC Tax, Finding Nexus Thresholds Are Not a Safe Harbor
In a recent case focusing on statutory interpretation, the California Office of Tax Appeals held that a Delaware LLC using Amazon’s Fulfillment by Amazon program was “doing business” in California and subject to the state’s annual $800 LLC tax. Read More >>
Alabama Tax Tribunal Interprets Statute of Limitations Ambiguity to Avoid Having Purchaser’s Refund Claims Time-Barred
State procedures for obtaining refunds of sales tax can be difficult to navigate for both purchasers and sellers. Read More >>
Sibling Rivalry: Florida v. California
While most of us with a brother or a sister are used to them tattling to the parents over some perceived slight (real or imagined), it is rare for such squabbles to play out in court. Read More >>
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. Read More »
© 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.
