In a decision with troubling potential implications, a Massachusetts appellate court held that a nonresident individual was subject to Commonwealth income tax on capital gain from the sale of his stock in the corporation that...more
A recent Supreme Court of Arkansas decision has upheld a multistate corporation’s allocation to Arkansas of 100% of its interest expenses from borrowings to fund a spin-off. It also rejected as irrelevant the state’s attempt...more
A recent New York City (“NYC”) determination limited the impact of the step transaction doctrine under the New York City real property transfer tax (“RPTT”). An Administrative Law Judge (“ALJ”) held that the collapsing of a...more
An investment management company subject to California corporate franchise tax was required to source its receipts from the provision of management, administrative, and distribution services furnished to mutual funds based on...more