Searching Content indexed under Corporate Tax by Robert Weyman ordered by Published Date Descending.
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REMIC Excess Inclusion Income – Is It Included In Net Income?
Corporations and financial institutions that hold REMIC residual interests may have a Massachusetts corporate excise tax refund opportunity.
United States
3 Oct 2017
Taxpayer Challenges Department Authority to Adjust NOL Carryforward, When NOL Was Generated in Tax Years Otherwise Closed by Statute
Can a Department of Revenue auditor reduce a taxpayer's deduction for a net operating loss ("NOL") carryforward, even if the NOL was generated in a tax year that is closed under the statute of limitations? This question is the subject of an appeal currently pending at the ATB.
United States
27 Sep 2017
Disallowance Of Deduction For Interest Paid To Hungarian Affiliate Serves As A Reminder Of Department's Continued Audit Scrutiny Of Intercompany Debt
A case recently resolved at the Appellate Tax Board serves as a reminder that Massachusetts' auditors continue to aggressively challenge the following intercompany transactions:
United States
13 Sep 2017
Filing Season Reminder: Revisions (And Challenges) To Alternative Apportionment Regulation
Any taxpayers considering taking an alternative apportionment position on its corporate excise tax returns this fall should remember that the Department adopted a revised alternative apportionment regulation...
United States
5 Sep 2017
Massachusetts SJC Reaffirms Decision Sourcing 100% Of Taxpayer's Loans To Massachusetts — Confirms Opportunity For Out-Of-State Financial Institutions
On Friday, August 12, the Massachusetts Supreme Judicial Court reaffirmed its decision in First Marblehead—that a financial institution that is commercially domiciled in Massachusetts can be required to source 100% of its loans to Massachusetts for purposes of computing its property factor numerator.
United States
16 Aug 2016
Massachusetts Court Issues 'True Debt' Decision
Yesterday, June 8, the Massachusetts Appeals Court once again denied a taxpayer's claimed deductions from the income and net worth tax base of the corporate excise tax.
United States
10 Jun 2016
Massachusetts Net Worth "True Debt" Litigation Moves Forward—Oral Argument Held, Awaiting Decision
With oral argument and briefing complete, the Massachusetts Department of Revenue's authority to increase the net worth component of a taxpayer's corporate excise using its "true debt" analysis is under review by the Appeals Court in National Grid Holdings, Inc. et. al. v. Commissioner.
United States
4 Mar 2016
Massachusetts Denies 'True Debt' Treatment For Cash Management Obligations
Importantly, the ATB's decision to uphold the assessment for purposes of the non-income measure of the corporate excise means that the "true debt" issue continues to be relevant for companies with cash management systems...
United States
9 Sep 2015
Massachusetts Tax Developments - June 2015
In this update, we'll look at the most recent developments in Massachusetts corporate tax, provide some administrative updates, and discuss some hot topics for the second half of 2015.
United States
24 Jun 2015
Appellate Tax Board Case Update: MassMutual Proves Intercompany Debt Is True Debt
Reed Smith will provide more analysis of the MassMutual decision and its implications for other taxpayers in its upcoming quarterly update.
United States
16 Jun 2015
First Marblehead Requests U.S. Supreme Court Review In SINAA Sourcing Appeal
The case involves the sourcing of securitized loans for property factor purposes under Massachusetts' rules for financial institutions.
United States
5 Jun 2015
Massachusetts Tax Developments - 6 March 2015
In this update, we'll look at the most recent developments in Massachusetts corporate tax, sales and use tax, and tax administration; and discuss some hot topics for 2015.
United States
10 Mar 2015
Massachusetts Promulgates Final Market Sourcing Regulation
This afternoon, the Massachusetts Department of Revenue promulgated its Final Regulation 830 CMR 63.38.1: Apportionment of Income, to implement the market-based sourcing rules.
United States
5 Jan 2015
Massachusetts Market Sourcing Update: Report From Public Hearing On Market Sourcing And Special Industry Apportionment Regulations
The Department of Revenue held a hearing for the public to present comment regarding the Department’s proposed market-based sourcing regulation.
United States
5 Dec 2014
ATB Upholds Single-Factor Apportionment For Manufacturer
On November 17, 2014, the Appellate Tax Board released its Findings of Fact and Report in Genentech v. Commissioner which held that a pharmaceutical company qualified as a "manufacturer" under Massachusetts law, and was required to apportion its corporate excise tax base using the single sales factor formula for manufacturing corporations, instead of the three factor formula.
United States
22 Nov 2014
Massachusetts Releases Second Draft Of Market Sourcing Regulations
The Massachusetts Department of Revenue released its Proposed Regulation 830 CMR 63.38.1: Apportionment of Income.
United States
3 Nov 2014
Massachusetts Tax Developments 14th October, 2014
Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update.
United States
15 Oct 2014
Massachusetts Tax Developments - Quarterly Update (4th Quarter 2013)
Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll take a look back to the developments from the last quarter of 2013, and look ahead to some percolating issues at the Appellate Tax Board ("ATB").
United States
25 Apr 2014
Commonwealth Faces Tough Questions From Appeals Court Justices In Sham Transaction Case
Last year the Appellate Tax Board issued a decision expanding the application of the sham transaction doctrine.
United States
22 Apr 2014
Corporate Members Of LLC Can Qualify As Mutual Fund Service Corporations
The Department ruled that the members of an LLC qualified as mutual fund services corporations for tax purposes.
United States
22 Apr 2014
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