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SALT Alert: Alabama Edition

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In a case of aboriginal consequence by an Alabama appellate court, the Alabama Cloister of Civil Appeals afresh advised an address by the Alabama Department of Revenue (ADOR) from an adverse ambit cloister cardinal involving whether “the taxpayer” (and we use that appellation abundantly as you will see) had appropriately appealed his appraisal back it was cryptic who the aborigine absolutely was—the distinct affiliate LLC (SMLLC) or the distinct affiliate himself. The absolute affair complex whether sales of prepaid allotment cardinal cards for corpuscle buzz casework were accountable to Alabama sales tax at the time the sales were fabricated (Alabama Department of Revenue v. Downing). The address time accomplished afresh so the accommodation is now final.

Alabama is one of a scattering of states that follows the Treasury Department’s check-the-box regulations not alone for purposes of accompaniment assets tax, but for sales, use, rental, lodging, and several added accompaniment taxes as able-bodied – but alone with account to LLCs. For added federally abandoned entities, such as Q-subs and abandoned bound partnerships, federal-state acquiescence stops at assets tax (see Ala. Code §10A-5A-1.07; ADOR Revenue Procedure 98-001 (Mar. 16, 1998); see additionally “Disharmony in Alabama’s Acquiescence to the Federal Tax Classification of Business Entities” in the March 2010 affair of The Alabama Lawyer).

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So, who is the able aborigine in an address of an ADOR or bounded tax appraisal involving a SMLLC? The sole member? The sole affiliate accomplishing business as the SMLLC? The SMLLC itself? Or maybe both? The ADOR adjourned Patrick Lee Downing as “the sole affiliate of Downing Enterprises, LLC, a abandoned entity” for contributed sales tax. He paid the appraisal but anon filed a affirmation for a acquittance with the ADOR in his alone name “d/b/a Downing Enterprises, LLC.” The acquittance affirmation was denied, and the SMLLC appealed to the Alabama Tax Tribunal, which affirmed the ADOR’s decision. Mr. Downing again appealed to the bounded ambit cloister as “sole member” of the SMLLC. The ambit cloister disqualified his way and ordered the ADOR to account his acquittance claim. The ADOR again appealed to the Cloister of Civil Appeals, alienated for the aboriginal time that the SMLLC had lacked continuing to address to the Tax Tribunal to activate with, and that “only Downing was the able party.”

The aborigine argued that for Alabama sales/use tax purposes, there’s no aberration amid himself and his SMLLC, citation Alabama’s broad-form adaptation of check-the-box acquiescence and the above-referenced ADOR Revenue Procedure. Indeed, the Alabama Tax Tribunal’s predecessor, the ADOR Administrative Law Division, had continued ago disqualified that way in Aboriginal American Holding, LLC v. ADOR.

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The Cloister of Civil Appeals adored the taxpayer’s (and maybe his attorney’s) bacon by acknowledging that Alabama absolutely conforms to the check-the-box regs for about all tax purposes with account to LLCs, and behindhand of whether the appraisal was issued to the alone or to the SMLLC, both had continuing to appeal.

As a abandoned entity, the LLC is not apparent from Mr. Downing for the purpose of ambrosial [to the Alabama Tax Tribunal], and the Department acknowledges that Mr. Downing would accept had continuing to address the abnegation of his address for acquittance to the Tax Tribunal. We accordingly achieve that the LLC additionally had continuing to address to the Tax Tribunal.

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Suffice to say, this is a cautionary account to tax practitioners who handle accompaniment or bounded tax disputes involving distinct affiliate LLCs – or added forms of federally abandoned entities such as Q-subs or abandoned bound partnerships, which may accept a altered rule. Although the aborigine won the procedural battle, he absent the absolute war, and he chose not to administer for certiorari to the Alabama Supreme Court.

Bruce Ely and Will Thistle are adept co-authors of a alternation of archive on the accompaniment taxation of LLCs and bound partnerships best afresh reprinted in Accompaniment Tax Notes. Will is additionally Chair of the Pass-Through Entities Subcommittee of the ABA Tax Section’s Accompaniment and Bounded Taxes (SALT) Committee.

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Upcoming Seminars/Speeches by Bradley SALT Practice Team Members:

ABA Tax Section Joint Fall Meeting, Atlanta, Georgia, October 4-6, 2018.—Bruce Ely is confined on a console discussing the assorted accompaniment responses to the TCJA’s $10,000 SALT answer limitation and the recently-issued IRS proposed regulations advised to stop these alleged “SALT cap workarounds.” Bruce Ely is additionally abstinent a console on the states’ responses to the new federal affiliation ysis rules, highlighting the archetypal statute actuality advocated by COST, AICPA, TEI, the ABA SALT Committee, IPT and others to the Multistate Tax Commission and the states. Will Thistle is speaking to the SALT Committee’s Executive Committee on contempo pass-through article developments.

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Annual Paul J. Hartman/Vanderbilt University SALT Forum, Nashville, Tennessee, October 17-19, 2018.—Bruce Ely is confined on a console discussing contempo developments in the accompaniment taxation of pass-through entities.

Council On Accompaniment Taxation (COST) Annual Meeting, Phoenix, Arizona, October 23-26, 2018.—Chris Grissom will be speaking on ‘Best Practices for Credits & Incentives Management and How to Prepare for FASB Topic 832 and New IRC 118’ as able-bodied as speaking on Alabama contempo tax developments. Bruce Ely will be confined on a console discussing contempo developments in the accompaniment taxation of pass-through entities with a focus on the archetypal affiliation ysis statute actuality advocated to the MTC and states by COST, AICPA, TEI, ABA SALT Committee and IPT.

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