Arthur R. Rosen

Arthur R. Rosen

McDermott Will & Emery

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New Jersey Division of Taxation’s 2014 Tax Resolution Initiative – Not To Be Confused With An Amnesty

The New Jersey Division of Taxation (Division) is trying to help taxpayers resolve unpaid tax liabilities for tax periods 2005 through 2013. Through November 17, 2014, the Division is offering taxpayers that pay all tax and...more

10/31/2014 - Tax Liability Tax Penalties Waivers

New Jersey Tax Court Finds Two Pennsylvania Taxes Are Not Required To Be Added Back

In a Corporation Business Tax (CBT) case, PPL Electric Utilities Corporation v. Director, Division of Taxation, Dkt. No. 000005-2011 (N.J. Tax. Ct. Oct. 2, 2014), the Tax Court of New Jersey found for the taxpayer and held...more

10/31/2014 - Corporate Net Income Corporate Taxes Gross Receipts Tax

Focus on Tax Controversy - Fall 2014

Supreme Court to Hear Tax Injunction Act Case - On August 20, 2013, in Direct Marketing Association v. Brohl, the U.S. Court of Appeals for the Tenth Circuit held that the federal Tax Injunction Act (TIA) prohibited...more

10/2/2014 - Brohl Certiorari Direct Marketing Association Discovery Electronically Stored Information Meal and Entertainment Expenditures Predictive Coding SCOTUS Sports Tax Court Tax Injunction Act

If At First You Don’t Succeed, Try, Try Again: Illinois General Assembly Sends Revised Version of Click-Through Nexus Law to the...

In 2011, Illinois became one of the first states to follow New York’s lead by enacting “click-through nexus” legislation. The Illinois law created nexus for any out-of-state retailer that contracted with a person in Illinois...more

7/31/2014 - Click-Through Nexus Nexus Retailers

Illinois Appellate Court’s Expansive Interpretation of a Taxing Ordinance Swallows a Sale for Resale Exemption

The First District of the Illinois Appellate Court, in Ford Motor Company v. Chicago Department of Revenue, 2014 IL App (1st) 130597 (June 27, 2014), recently held that Ford Motor Company (Ford) owes City of Chicago vehicle...more

7/31/2014 - Auto Manufacturers Car Dealerships Ford Motor Fuel Tax Manufacturers Resale Exemption

The Vermont Department of Taxes Begins to Take a Close Look at Cloud Computing

On June 30, 2013, the Vermont sales tax moratorium on remote access to software expired. At that time, the Vermont Department of Taxes (Department) reverted to its prior position that interpreted, without any analysis, the...more

7/30/2014 - Cloud Computing Licenses Moratorium Open Source Software Proposed Regulation Sales & Use Tax Software Software Developers

New Jersey Tax Court Issues Important Order on the State’s Throw Out Rule

The Tax Court of New Jersey recently issued an important order that may have eviscerated the impact of the Throw Out Rule on intangibles holding companies. On its face the order does not appear to address the application of...more

9/9/2013 - Commerce Clause Due Process Intangible Holding Company New Regulations Nexus

New York Issues First New Combined Reporting Law Determination—and It’s Not Pretty

Even though New York amended its combination statute for years beginning in 2007, we are just now beginning to see litigation related to those amendments. At the end of June 2013, an administrative law judge in New York’s...more

7/8/2013 - ALJ Child Care Combined Reporting Corporate Taxes Income Taxes Mandatory Reporting Laws New Legislation

N.Y. ALJ Holds Taxpayer’s Motives for Acquiring Stock and How Stock Is Used Irrelevant in Determining Investment Capital

A New York administrative law judge recently held in Matter of C.V. Starr & Co., Inc. that income received by a taxpayer from its ownership of common stock was investment income. In so holding, the ALJ addressed an important...more

5/22/2013 - AIG Income Taxes Net Investment Income Stocks

National Conference of State Legislatures to Tackle Key State Tax Policy Questions

The National Conference of State Legislatures’ (NCSL) Executive Committee Task Force on State and Local Taxation has expanded its scope to include all significant tax policy issues facing the states. As part of its expanded...more

3/7/2013 - National Conference of State Legislatures State Taxes

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