Craig Fields

Craig Fields

Morrison & Foerster LLP

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North Carolina Alters Sales Factor for Certain Royalty Recipients

Effective May 11, 2016, the North Carolina General Assembly amended the royalty reporting option contained in Section 105-130.7A(a). As a result of the amendment, even if royalty payments are added back to the royalty...more

8/25/2016 - Amended Legislation Apportionment Business Taxes Royalties Sales Factor State and Local Government

Throwout: New Jersey Supreme Court Denies Certification

The New Jersey Supreme Court has denied certification in Lorillard Licensing Company LLC v. Director, Division of Taxation, making the Appellate Division's decision final. The Appellate Division affirmed the Tax Court in its...more

6/22/2016 - Business Taxes Corporate Taxes Double Taxation Nexus NJ Supreme Court Standard of Review Tax Court Throwout Rule

Out-of-State Subsidiary Holding Company Cannot Be Forcibly Included in a Colorado Combined Return

A Denver District Court judge has held that the Colorado Department of Revenue cannot forcibly combine a corporation’s subsidiary, a holding company that derived its income solely from investments in foreign entities, in...more

1/25/2016 - Combined Reporting Department of Revenue Foreign Entities Foreign Investment Internal Revenue Code (IRC) Section 482 Subsidiaries

New Jersey Tax Court Publishes Decisions That Dual Nexus Standards Are Inappropriate For Throwout

On January 6, 2016, the New Jersey Tax Court approved its January 14, 2014 decision in Lorillard Licensing Company LLC v. Director, Division of Taxation for publication, making the Tax Court decision precedential. The...more

1/7/2016 - Business Taxes Corporate Taxes Nexus NJ Supreme Court Standard of Review Tax Court

New Jersey Files Notice of Petition for Certification After Appellate Division Affirms That Dual Nexus Standards Are Inappropriate...

New Jersey filed a notice of petition for certification (request for discretionary review) with the New Jersey Supreme Court seeking reversal of the Appellate Division’s December 4, 2015 decision that the Division may not...more

12/31/2015 - Business Taxes Corporate Taxes Nexus NJ Supreme Court Petition for Writ of Certiorari

Scudder Appointed Acting Treasurer of New Jersey Has Tax and Economics Backgrounds

Mr. Scudder’s leadership is scheduled to commence on November 9, 2015. Mr. Scudder returns to his native New Jersey from his dual roles as Chief Operating Officer of economic research and consulting firm Laffer...more

10/30/2015 - Administrative Appointments State Treasurers Treasury

Michigan Court of Appeals Upholds the Constitutionality of the State’s Retroactive Repeal of the Multistate Tax Compact

The Michigan Court of Appeals affirmed the Court of Claims’ decisions in cases that challenged the constitutionality of Michigan’s purported retroactive repeal of the Multistate Tax Compact effective January 1, 2008. The...more

10/5/2015 - Appeals Multistate Tax Compact Repeal Retroactivity

New York State Tax Department Releases Draft Corporate Tax Nexus Regulations for Comment

On September 2, 2015, the New York State Department of Taxation and Finance released draft amendments to the Article 9-A corporate franchise tax regulations to address significant changes relating to statutory nexus under...more

9/9/2015 - Comment Period Corporate Taxes Economic Presence Nexus Franchise Taxes Proposed Amendments Tax Reform

Indiana DOR Finds Economic Nexus, Disregards UPS

The Indiana Department of Revenue recently concluded that a company that earned royalty income from licensing trademarks and trade names to two of its Indiana affiliates, and had no physical presence in the state, nonetheless...more

9/10/2014 - Corporate Taxes Department of Revenue Foreign Entities License Agreements Patents Reinsurance Royalties Trademarks UPS

State + Local Tax Insights -- Winter 2014

In This Issue: Ringing in the New Year: Issues from 2013 That Will Likely Impact 2014; Upcoming Speaking Engagements; Defending Against Penalties; and Dueling “Doing Business” Interstate-Commerce Exemptions:...more

1/15/2014 - Internet Taxation Interstate Commerce Penalties SALT State Taxes Tax Reform

New Jersey Throwout: Tax Court Amplifies Its No Dual Nexus Decision

The New Jersey Tax Court issued a written amplification of its bench decision in Lorillard Licensing Company LLC’s appeal that the Division of Taxation may not apply dual nexus standards for Throwout purposes. In...more

1/15/2014 - Nexus Tax Court Whirlpool

State + Local Tax Insights -- Fall 2013

In This Issue: “Occasional Sales” and Single Sales Factor Apportionment in California; Upcoming Speaking Engagements; State Taxation of Financial Institutions; Applying the True Object Test to Determine the Taxability...more

10/29/2013 - Apportionment Economic Presence Nexus Franchise Taxes SALT State Taxes

Economic Nexus Curtailed, Again

Introduction - In a period of 18 months, three state courts have refused to extend economic nexus approaches to the facts before them, despite prior decisions in those states that corporations without physical presence...more

10/21/2013 - Corporate Taxes Nexus

New Jersey Tax Court Issues Bench Ruling That Dual Nexus Standards Are Inappropriate In Applying Throwout

In response to numerous inquiries for copies of our Transcript of ruling and argument following our August 22, 2013 alert, of the New Jersey Tax Court’s bench ruling that the Division of Taxation may not apply dual nexus...more

9/12/2013 - Nexus State Taxes

‘Inherited’ Nexus And Other Extreme Nexus Theories

Nexus — whether a corporation has a sufficient connection such that it may be taxed by a state — is one of the most important issues in state tax. Various legal theories have been asserted (and are being asserted) to justify...more

7/15/2013 - Business Taxes Corporate Taxes Due Process Jurisdiction Nexus Sufficient Nexus

State and Local Tax Insights -- Winter 2013

In This Issue: Sales Tax Nexus Developments in California and Beyond: A Year in Review; Upcoming 2013 Speaking Engagements; Recent MoFo State + Local Taxpayer Victories; Exploring the Subject to Tax Exception to Addback...more

1/24/2013 - Amazon Internet Internet Retailers Sales & Use Tax

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