Council On State Taxation
Impact of Federal Reform on State
Corporate Income Tax Base & the Best
and Worst of Sales Tax Administration—
Focus on New Mexico
Nikki Dobay
Senior Tax Counsel (COST)
2018 15th Annual NMTRI
Tax Policy Conference
1
Agenda
– Impact of Federal Tax Reform on the State
Corporate Income Tax Base
▪ Overview and Fiscal Impact of the Tax Cuts
and Jobs Act
▪ State Conformity and Non-Conformity Overview
▪ Key TCJA Provisions and the State Tax Impact
– The Best and Worst of Sales Tax
Administration
2
Key Tax Law Changes in the TCJA
– Lower Tax Rates
▪ Reduces individual and corporate income tax rates (40% rate cut)
▪ New 20% deduction for certain pass-through entity income
– Base Broadening
▪ Lower rates are offset significantly by a wide range of individual and
business taxation base broadeners
▪ Examples: broad limitations on the deductibility of interest deductions and
$10k limitation on state and local tax deductions for individuals
– International Tax Reform
▪ Moves the U.S. from a worldwide to a quasi-territorial tax system
consistent with U.S. trading partners
▪ One-time transition tax on previously untaxed accumulated foreign
earnings
▪ New foreign source tax provisions intended to raise revenues (to offset
tax cuts) and tilt the playing field to favor domestic commerce over
foreign commerce
4
Differential Federal and State Fiscal Impacts
of TCJA
– According to the Joint Committee on Taxation, at the federal
level, TCJA will result in about $6 trillion in tax cuts offset by
about $4.5 trillion in revenue raisers over the first 10 years
▪ Individual tax cuts over 10 years: $1.127 trillion (most sunset on
12/31/25)
▪ Corporate tax cuts over 10 years: $329.4 billion (10% decrease in
corporate tax base)
– Conversely, at the state level, TCJA will likely result in an
increase of approximately 12% in the corporate tax base
▪ Generally states do not conform to the federal provisions that
lower revenue (e.g., tax rate cuts), but do conform to many federal
provisions that increase revenue (e.g., base-broadening
measures)
5
Quantifying the impacts of TCJA on state corporate
taxes
– New EY/COST/STRI study provides
estimates of the impacts of TCJA on
state corporate tax bases.
– Study examines the impact of all
states updating their corporate tax
codes to the TCJA, but remaining
coupled to specific provisions as they
have in the past.
– The estimated percentage change in
the state corporate tax base from
TCJA is about 12 percent over the
first 10 years (2018-2027), with
significant variation among the
states.
6
7
State% increase in state corporate tax base State
% increase in state corporate tax base
Alabama 11% Nebraska 11%
Alaska* 12% Nevada n/aArizona 14% New Hampshire* 13%
Arkansas 12% New Jersey* 12%
California** 12% New Mexico* 11%
Colorado 12% New York* 12%
Connecticut* 12% North Carolina 12%
Delaware 10% North Dakota 10%
Florida 13% Ohio n/a
Georgia 12% Oklahoma 13%
Hawaii* 13% Oregon* 10%
Idaho 9% Pennsylvania* 14%
Illinois 9% Rhode Island* 11%
Indiana* 12% South Carolina 12%
Iowa 13% South Dakota n/a
Kansas 11% Tennessee* 12%
Kentucky* 12% Texas n/a
Louisiana 12% Utah* 12%
Maine 12% Vermont 14%
Maryland* 12% Virginia 13%
Massachusetts* 12% Washington n/a
Michigan 9% West Virginia 9%
Minnesota* 12% Wisconsin* 9%
Mississippi* 4% Wyoming n/a
Missouri 11% District of Columbia 12%
Montana* 9% Overall Change 12%
Estimated percentage change in state corporate tax base
from TCJA, by state (2018-2027)* State starts with
Form 1120 line
28. To the extent
IRC Section 250
deductions not
allowed, this
impact would be
higher by 4.5%.
** There may be a
California impact
relating to cash
repatriation for
waters’-edge filers
once the deemed
repatriated
earnings have
been actually
distributed as
dividends to U.S.
corporate
shareholders.
California has
estimated this
amount at
approximately
$350 million.
State income tax conformity to IRC
AK
HI
ME
VT
NH
MANYCT
PA
WV
NC
SC
GA
FL
ILOH
IN
MI
WI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
COUT
WY
MT
OR
ID
NV
CAVA
Key
Fixed
Rolling
Selective
No income tax
As of March 6, 2018
Note - CA & MA personal income tax law differs in its conformity to the IRC compared to CA & MA corporate tax law.
RI
NJ
DE
DC
Note - OH doesn’t have a corporate income tax. Personal income tax IRC adoption is Fixed
WA
9
Note – MI IRC conformity is January 2012 or if elected by Taxpayer Current Year (i.e. Rolling)
MD
Potential State Impact of Business Tax Reform Provisions
Federal States
Corporate tax rate reductions States have own rates
Special pass through entity deduction
Potentially impacts minority of states tied
to federal “taxable income” for PIT
purposes
Limitation of net interest deductions that
exceed 30% of adjusted taxable income
Mostly state conformity (uncertain
application to state filing groups)
Fully expensed investments2/3 of states opted out of bonus
depreciation
Broadened tax base including repeal of
Sec. 199 domestic production deduction
State conformity (although many states
already opted out of the domestic
production deduction)
Limit NOL deductionsMost states have their own NOL
provisions
Amortization of research and
experimental expendituresLikely state conformity
10
Potential State Impact of International Tax Reform Provisions
Federal States100 percent dividends-received deduction (DRD)
Most states have their own DRDs
Transition tax on “deemed” repatriated earnings
One-third of states tax some portion of Subpart F income and/or foreign dividends.
Tax on global intangible low-taxed income (GILTI) earned by foreign subsidiaries
Mostly state conformity (but constitutional limitations)
Deduction of 50 percent of GILTI income Mostly state conformity (but “special deduction” linkage issues)
Reduced tax on foreign-derived intangible income (FDII) of U.S. corporation
Mostly state conformity (but “special deduction” linkage issues)
Base erosion anti-avoidance tax (BEAT) Separate tax not in federal taxable income
Longer amortization schedule for foreign research and experimentation (15 years)
Likely state conformity (but constitutional issues)
11
Business Tax Provision% Change in
Federal Corporate Tax Base
State Conformity
One-time transition tax on unrepatriated foreign earnings
+ 9 %Modest conformity (but
typically of 25% or less)
Net interest expense limitation (30% of ATI) + 6.4% Mostly conformity
Global intangible low-taxed income (GILTI) + 5.5 % (gross
amount)Mostly Conformity
Modification of net operating loss deduction + 5.3% Mostly non-conformity
Base Erosion and Anti-Abuse Tax (BEAT) + 4.0% Non-conformity
Amortization of research and experimental expenditures
+ 2.9% Mostly Conformity
Repeal of domestic production activities deduction + 1.9% Mostly conformity
Foreign derived intangible income (FoDII) deduction - 1.7% Mostly conformity
Expensing provided under Section 168(k) bonus depreciation
- 1.8% Modest conformity
Global intangible low-taxed income (GILTI) deduction - 2.6% Mostly conformity
100% foreign DRD - 5.9% Mostly conformity
Top Increases and Decreases in Federal Corporate Tax Base
with TCJA and Potential State Conformity
12
AK
HI
ME
RI
VT
NH
MANYCT
PANJ
DC
DE
WV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
CO
UT
WY
MT
WA
OR
ID
NV
CAVA
MD
State Income Starting Point
Source: COST/STRI/EY study
Line 30
Line 28
Gross receipts tax or no corporate income tax
Other
This analysis assumes each state will update to the 2018 IRC consistent with the provisions the state conformed to prior to the enactment of the
TCJA. This map is intended for general information purposes only and should not be relied upon for tax advice.
14
Transition Tax: IRC §965
– Imposes a one-time transition tax on a U.S. shareholder with respect
to its investment in CFCs and certain other foreign corporations
– Imposed on the net aggregate amount of the U.S. shareholder’s pro
rata shares of the previously untaxed foreign earnings and profits
(“E&P”) of such CFCs and other foreign corporations
▪ Effective rate of 15.5% on the amount of cash and cash equivalents, and 8%
for any amount in excess
– Reported on return of U.S. shareholders for the last taxable year of
the foreign corporation beginning before January 1, 2018, but
taxpayers are able to elect to pay any resulting liability over an eight-
year period.
– IR-2018-53 (March 13, 2018):
▪ Transition tax base is reportable on a separate “IRC 965 Transition Tax
Statement.”
▪ Resultant tax liability reported on line 31 of Page 1 of Form 1120 (Total
tax).
15
AK
HI
ME
RI
VT
NH
MANYCT
PANJ
DC
DE
WV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
CO
UT
WY
MT
WA
OR
ID
NV
CAVA
MD
Potential State Taxation of Accumulated Foreign
Earnings
Source: COST/STRI/EY study
Assumes no impact
Assumes partial or full impact
California special treatment
This analysis assumes each state will update to the 2018 IRC consistent with the provisions the state conformed to prior to the enactment of the
TCJA. This map is intended for general information purposes only and should not be relied upon for tax advice.
16
Transition Tax: SALT Implications
– Impact is largely based on:
▪ States’ starting point for calculation of state taxable income: the
transition tax is reported and calculated on a separate IRC 965
Transition Tax Statement, with the liability going into line 31 and
line 32 of Form 1120.
▪ State treatment of subpart F income
▪ State adoption of IRC §965 (c) (effectively providing reduced
tax rates)
▪ Taxpayers’ state income tax filing method – worldwide
combined, water’s-edge, or separate
17
Transition Tax: SALT Implications
– Timing—States traditionally do not afford a similar
payment deferral mechanism as allowed for federal
income tax purposes
– Conforming states may run afoul of Kraft
– Factor representation - Is the inclusion of foreign
(deemed) dividends, but not including the corresponding
apportionment factors of the specified foreign
corporations unconstitutionally discriminatory?
18
GILTI: IRC §§951A and 250
– Imposes tax on a U.S. taxpayer’s GILTI: CFC income in excess of a
proxy for routine returns (e.g. in excess of 10% rate of return) on
tangible property (measured based on adjusted tax basis)
– A 50% deduction for such income is provided, generally resulting in
a U.S. tax rate of 10.5% for such income (13.125% after 2025)
– GILTI is specifically not considered Subpart F income for Federal
purposes except where IRC §951A otherwise says it is
– Foreign tax credits (“FTCs”) are permitted for 80% of the foreign
taxes paid with respect to such income, assuming average foreign
tax rate imposed on such income is at least 13.125%
19
AK
HI
ME
RI
VT
NH
MANYCT
PANJ
DC
DE
WV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
CO
UT
WY
MT
WA
OR
ID
NV
CAVA
MD
Potential Taxation of GILTI Income (Inclusion)
Source: COST/STRI/EY study
No exclusion of 951-964 income
Excludes 951-964 income
Gross receipts tax
States that have delinked from GILTI
This analysis assumes each state will update to the 2018 IRC consistent with the provisions the state conformed to prior to the enactment of the
TCJA. This map is intended for general information purposes only and should not be relied upon for tax advice.
20
GILTI: SALT Implications
– Potential base broadening
– Because IRC §951A is a new section, states will generally not have
a specific exclusion for GILTI
– If IRC §250 is considered a “special deduction,” the impact of the
corresponding deduction in IRC §250 is largely dependent on
states’ starting point for calculating state taxable income:
▪ Form 1120 line 28 – income before NOLs and special
deductions vs. line 30 – income after NOLs and special
deductions
– Splitting of IRC §951A and IRC §250 – providing for inclusion
without deduction
21
GILTI: SALT Implications
– Disconnect from federal treatment, as states generally
do not permit use of FTCs
– The impact of GILTI will be affected by a taxpayer’s
state income tax filing method
– Kraft issues
– Factor representation—Is the inclusion of foreign
(deemed) dividends, but not including the corresponding
apportionment factors of the CFCs unconstitutionally
discriminatory?22
FDII: IRC §250
– Provides a 37.5% deduction for certain income earned
in the U.S. attributed to foreign exploitation of U.S.-held
intangibles
▪ Results in a reduced effective tax rate on covered
income of 13.125%, subject to a taxable income
limitation (16.40625% after 2025)
– FDII is calculated in a manner similar to GILTI. Returns
in excess of 10% of fixed assets form the basis for the
calculation
23
FDII: SALT Implications
– Deduction for FDII under IRC § 250 is likely a “special
deduction,” thus the impact (benefit) is largely
dependent on whether a state’s starting point for
calculation of state taxable income is Form 1120 line 28
or line 30
– The impact of FDII will be affected by a taxpayer’s state
income tax filing method
– Selective decoupling – FDII, as enacted, is to work with
GILTI
24
BEAT: IRC §59A
– Generally imposes a 10% minimum tax (5% in 2018) on a
taxpayer’s income determined without regard to tax deductions
arising from base erosion payments.
– Base erosion payments: generally amounts paid by a taxpayer to a
related foreign person that are deductible to the taxpayer (including
interest) or that create depreciable or amortizable asset basis.
– The BEAT applies to U.S. corporations (other than RICs, REITs, or
S corporations), which have average annual gross receipts of at
least $500 million for the preceding three tax years and which have
a base erosion percentage (generally, deductible payments to
foreign affiliates over total deductions) of 3% (2% for affiliated
groups that include a bank or securities dealer) or higher for the tax
year.
25
BEAT: SALT Implications
– The federal impact of the BEAT is the payment of
additional tax for those taxpayers subject to it
– Because the BEAT is a separate tax that does not go
into the calculation of federal taxable income, the BEAT
currently does not have an impact on state taxable
income
26
Interest Expense Limitation – IRC § 163(j)
• General Overview: Business interest expense cannot
exceed 30% of FTI exclusive of business interest income,
business interest expense, depreciation, amortization.
• State Tax Issues:
▪ How is the limitation computed for state purposes
when the state and federal filing methodologies differ?
▪ External vs. internal debt?
▪ Will state allow indefinite carryforward of disallowed
interest expense?
▪ How will the federal limits interact with state related
party interest expense disallowance statutes?
27
100% Bonus Depreciation – IRC §168(k)
• General Overview: Current bonus depreciation
percentage under IRC § 168(k) is increased from 50% to
100% for property acquired and placed in service after
September 27, 2017, and before December 31, 2022. The
100% expensing is phased down by 20 percentage points
per calendar year beginning in 2023.
• State Tax Issues:
• Will states conform?
• In state that historically decoupled from bonus, will
they decouple from the increase to 100%?
▪ Straight coupling to federal vs. MACRS vs. different
approaches
▪ Having to track different methods in different states28
COST Conformity Principles
– Manage conformity to achieve revenue neutrality and
avoid increasing the state’s business tax burden
– Do not selectively conform to revenue-increasing federal
tax reform changes only
▪ Example: GILTI but not IRC Section 250 deduction.
▪ Example: Interest deduction limitation but not 100%
expensing
– Do not conform to new foreign source income provisions
that would expand the state tax base beyond the water’s
edge
▪ Examples: GILTI; BEAT
– States should provide guidance to facilitate state income
tax compliance with complex new federal tax reform
provisions.29
State Conformity Changes: Base Narrowing
Legislation as of mid-April 2018
– Corporate Rate Cuts Following Federal Tax Reform
▪ FL (H.B. 7093); GA (H.B. 918); ID (H.B. 463)
– General Decoupling from TCJA Base Broadeners
▪ WI (A.B. 259) – decoupled from Interest Expense Limit, GILTI, FDII, R
& E amortization, Full Expensing, BEAT, Repatriation
– Decoupling from Interest Expense Limitation
▪ GA (H.B. 918); MS (no conformity due to preexisting law)
▪ Tenn. (in 2020)
– Decoupling from GILTI
▪ GA (S.B. 328);
▪ IL, MI, MT, WI (no conformity due to preexisting law)
– Allowing GILTI Deductions
▪ NY (DTF statement that IRC 250 deductions included; FDII decoupled
in budget)
– Transition Tax Installment Payments
▪ UT (S.B. 244)
Background on COST’s Scorecards
– Purpose of Scorecards is to grade the state tax administration on an
objective basis and to work with the states’ policy makers – both
executive and legislative – to improve state and local tax
administration for multijurisdictional businesses
– Other COST Scorecards:
▪ State Administrative Scorecard—increase in independent
tribunals & appeal period from 30 to 60 days
▪ Unclaimed Property Scorecard—increase in states exempting gift
cards and business-to-business transactions
▪ Property Tax Administration Scorecard
▪ International and improvement of some states appeal processes
32
The Sales Tax Scorecard Categories
– Exemption for Business-to-Business Transactions
– Fair Sales Tax Administration
– Centralized Sales Tax Administration
– Simplification & Transparency
– Reasonable Tax Payment Administration
– Fair Audit/Refund Procedures
– Other Issues Impacting Fair Tax Administration
– What the Scorecard Does Not Grade
▪ Tax Rate Differences
▪ Tax Base Breadth (other than Taxing Business Inputs)
33
38%
21%
12%
9%
6%
68%
Source: COST, STRI, Ernst & Young: “Total State and Local Business Taxes: State-by-State Estimates for Fiscal Year 2016”
Taxes on business property
Sales tax on business inputs
Excise, utility & Insurance taxes
Corporate income tax
Unemployment insurance tax
Individual income tax on business income
Business license, severance & other taxes
United States
Sales Taxes Make Up of
Overall Business State and Local Taxes
20%
42%
11%
4%
7%
2%
16%
New Mexico
34
AK
HI
ME
RI
VT
NH
MANYCT
PANJ
DC
DE
WV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
CO
UT
WY
MT
WA
OR
ID
NV
CAVA
MD
N/A A B C D F
N/A 0-9 10-13 14-17 18-22 22+
35
States’ Overall Grades
Exemption for Business-to-Business Transactions
– COST/EY Study highlighting overall tax on business inputs – 2
points
– Manufacturing exemption – 3 points
▪ Manufacturing equipment exemption – 2 points
▪ Manufacturing inputs exemption – 1 point
– Pyramiding tax of service industries – 3 points
▪ Double tax on equipment to provide service and tax on
service when sold to consumer
– New Mexico’s Score – 8 (out of 8) points
36
AK
HI
ME
RI
VT
NH
MANYCT
PANJ
DC
DE
WV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
CO
UT
WY
MT
WA
OR
ID
NV
CAVA
MD
N/A A B C D F
N/A 0-1 pts 2 pts 3-4 pts 5-6 pts 7-8 pts
37
Exemption for Business Inputs – States’ Grades
State and Local Sales Taxes Imposed on Business Inputs over Business Inputs Share of Total Sales
Tax Collected
47%
32%
37%
32%
46%
39%
37%
33%60%
42%
58%
48%
52%
41%
44%
58%
46%
42%
47%
39%
37% 32%
37%
41%
36% 35%
43%
40%
42%
40%
41%
37%
44%
42%
36% DC 42%
MD 42%
NJ 43%
42%
CT 39%
RI 36%
MA 48%
VT 51%
35%
40%
44%
HI 36%
38
25% - 35% 36% - 45% 46% + States With No Sales Tax
N/A
N/A
N/A
N/A
Breadth of States’ Manufacturing Equipment Exemptions
39
32% DCMDNJ
CTRIMAVT
HI
None or Restricted Exemption Direct or Primary Use Exemption Integrated Plant Exemption
States with No Sales TaxWA
OR
CA
NV
AZ
AK
ID
MT
WY
UT
ND
SD
NE
CO
NM
KS
OK
MN
IA
MO
AR
TX
WI
MI
IL IN
KY
TN
MS
LA
AL GA
FL
SC
NC
VAWV
OH
PA
NY
VTNH
ME
MACT
NJMD
Double Taxation of Select Service Providers: Wired/Wireless, Cable, Electric and Gas
No Double Tax
1 Service Industry Double Taxed 3 Service Industries Double Taxed2 Service Industries Double Taxed
40
States with No Sales Tax
32% DCMDNJ
CTRIMAVT
HI
WA
ORID
CA
NV
MT
WY
UT
AZ
CO
ND
SD
NE
KS
NM
TX
AK
MN
WI
MI
IA
MO
OK AR
LA
TN
MS
IL INOH
PA
NY
VT
ME
NH
WVVA
NC
SC
GAAL
FL
MDNJ
MACT
Fair Sales Tax Administration
– Exemption Certificate Procedure - 2 points
▪ Good faith on acceptance
▪ 120-day period on audit to perfect
▪ Allow MTC or SSUTA certificate
▪ Verification of exemption/account number
– Vendor Compensation – 2 points
▪ No vendor comp. or less than $12,000 per year (de minimis) - 2 points
▪ At least 0.5% for one-rate state or 0.75% for states with local rates – no
points
– Broad Direct Pay – 1 point
▪ Not overly restrictive – no thresholds over $1 million per year
– New Mexico’s Score – 5 (out of 5) points
41
Centralized Sales Tax Administration
– Population of state as compared to number of local jurisdictions - 1
point
▪ Less than 20,000 – 1 point
– Central administration – 3 points
▪ Uniform tax base
▪ Centralized filing and auditing
▪ Centralized appeals
– Website has current & historical tax rates and boundaries – 1 point
– New Mexico’s Score – 2 (out of 4) points
47
Simplification & Transparency
– SSUTA State - 2 points
– Tax on digital products and prewritten software – 2 points
▪ Is by legislation or administrative rule/policy position?
– Liability relief – 1 point
▪ Relief should broadly apply to most written
correspondence
– New Mexico’s Score – 4 (out of 5) points
52
Taxation of a Person Merely Accessing Pre-Written Software
AK
HI
ME
RI
VT
NH
MANYCT
PA
NJ
DC
DE
WV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
CO
UT
WY
MT
WA
OR
ID
NV
CAVA
MD
No Tax Imposed Tax Imposed Without Statutory Authority
56
Tax Imposed by Statutory Authority
States With No Sales Tax
Reasonable Tax Payment Administration
– Advance Payments - 2 points
▪ One per year or month – 1 point
▪ Two or more per month – 2 points
– Full credit other states sales/use taxes – 2 points
▪ Credit sales and use tax – 1 point
▪ Credit other states’ state and local taxes – 1 point
– Periodic leases tax based on each lease payment – 2 points
▪ State accelerating or continuing tax on leases when property no longer in the state
– 1 point
▪ Credit for tax paid in other states on such leases- 1 point
– Bad debt deduction applies to third-party private label credit card – 1 point
– New Mexico’s Score – 3 (out of 7) points
58
Advance Payments
AK
HI
ME
RI
VT
NH
MANYCT
PA
NJ
DC
DE
WV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
CO
UT
WY
MT
WA
OR
ID
NV
CAVA
MD
No Advance Payments 1 Advance Payment Per Month or Year
60
More Than 1 Advance Payment Per Month
States with no sales tax
Fair Audit/Refund Procedures
– Purchasers ability to obtain refunds directly from the state
- 1 point
– False claims act & class action suits – 2 points
▪ Allow either – 1 point each
– Contingent fee or private auditing – 1 point
▪ Allow either – 1 point
– New Mexico’s Score – 1 (out of 4) points
64
AK
HI
ME
RI
VTNHMANY
CT
PANJ
MDDE
VAWV
NC
SC
GA
FL
ILOHIN
MIWI
KY
TN*
ALMS
AR
LATX
OK
MOKS
IA
MN ND
SD
NE
NMAZ
CO*UT
WY
MT
WA
OR
ID
NV
CA*
DC
Accelerated Lease Payments (ALPs)
No ALPs With Credit
ALPs and Continued Tax on Leases With Credit
67
No ALPs, No Credit
ALPs and Continued Tax on Leases With No Credit*CA, CO, TN: Continues tax on certain lease payments using origin location
SSN and Other Issues
AK
HI
ME
RI
VTNH
MANYCT
PANJ
DC
DEWV
NC
SC
GA
FL
ILOH
IN
MIWI
KY
TN
ALMS
AR
LATX
OK
MOKS
IA
MN
ND
SD
NE
NMAZ
COUT
WY
MT
WA
OR
ID
NV
CAVA
MD
70
SSN and/or Home Addresses Other Issues