The BR State + Local Tax Spotlight: July 2021

The BR State + Local Spotlight
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Note from the Editors

Welcome to the July 2021 edition of The BR State + Local Tax Spotlight. We understand the unique demands of staying on top of important State + Local Tax developments, which happen frequently and across numerous jurisdictions. Staying updated on significant legislative developments and judicial decisions helps tax departments function more efficiently and improves strategy and planning. That is where The BR State + Local Tax Spotlight can help. In each edition, we will highlight for you important State + Local Tax developments that could impact your business. In this issue, we will be covering:

  • A recent voluntary compliance initiative launched by the New Jersey Department of Taxation for certain companies included in combined corporation business tax returns;
  • A new Connecticut budget law that extends the corporation business tax surcharge, delays the capital base tax phaseout, and creates a tax amnesty program;
  • A recent release of guidance from the City of Philadelphia that terminates temporary COVID-19-related policies under several local business taxes; and
  • A recent report issued by a Special Master appointed by the U.S. Supreme Court concluding that Delaware was not entitled to escheat the unclaimed proceeds of certain “Official Checks” issued by MoneyGram.

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.

— Matthew F. Cammarata and Eugene J. Gibilaro


New Jersey Announces CBT Voluntary Compliance Initiative for Companies Included in Combined Returns
By Mitchell A. Newmark

The New Jersey Division of Taxation (“Division”) recently extended an invitation for voluntary compliance with limited look-back and penalty waiver to companies that were included in mandatory unitary combined returns and indicated that they have nexus with New Jersey but did not file separate entity returns prior to 2019 (the year New Jersey started mandatory combined filing for most corporations) via its Combined Reporting Initiative for Corporation Business Tax (New Jersey’s corporate income tax). Read More »

Connecticut Enacts Budget Bill Extending Business Tax Surcharge, Delaying Capital Base Tax Phaseout, and Creating a Tax Amnesty Program
By Kara M. Kraman

On June 23, 2021, Connecticut Governor Ned Lamont signed into law two budget bills comprising the state budget for the fiscal year 2022-2023 (the “Budget Bill”). H.B. 6689, S.B. 1202. The Budget Bill contained several noteworthy tax provisions, including extending the corporation business tax surcharge for an additional two years, delaying the phase-out of the capital base tax on corporations, and creating a tax amnesty program. These provisions are discussed below. Read More »

City of Philadelphia Ends Temporary COVID-19 Tax Policies
By Irwin M. Slomka

Now that the COVID-19 pandemic has dissipated, states and localities have begun to end temporary tax policies that were meant to provide relief to some taxpayers from the restrictions imposed by government during the pandemic. The City of Philadelphia has released new guidance explaining the termination of temporary policies under several local business taxes, including the effect of employees working from home on nexus. Read More »

Delaware’s Arguments Fall Short: Supreme Court Special Master Finds That MoneyGram’s Unclaimed “Official Checks” Should Escheat to States Where Purchased
By Hollis L. Hyans

In an action brought under the original jurisdiction of the U.S. Supreme Court, 30 states disputed Delaware’s entitlement to escheat the unclaimed proceeds of certain “Official Checks” issued by MoneyGram. A Special Master appointed by the Supreme Court has now issued a lengthy report, concluding that the instruments in question are either “money orders” or “similar instruments,” and therefore, under a federal statute, escheat not to Delaware—the state of incorporation of MoneyGram—but rather to the states where the instruments were purchased. Read More »


Please join us as we return in person for our annual State + Local Tax Summit, which will be held on Friday, August 13, 2021, at Blank Rome LLP’s New York office. The Summit will include timely and important discussion of the state and local issues affecting your company. Learn More »

© 2021 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.