Jeffrey Friedman

Jeffrey Friedman

Sutherland Asbill & Brennan LLP

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California Supreme Court Holds Multistate Tax Compact is Not Binding

On December 31, 2015, the California Supreme Court closed the book on California’s Multistate Tax Compact election saga, unanimously holding that the Compact is not a binding contract among its members and the State was not...more

1/5/2016 - CA Supreme Court Corporate Taxes Franchise Tax Board Gillette v Franchise Tax Board Multistate Corporations Multistate Tax Commission Multistate Tax Compact Tax Increases

Back in Court: DMA Argues Before the Tenth Circuit to Follow Quill

Direct Marketing Association (DMA) continued its fight against Colorado’s use tax reporting regime during oral arguments today before the United States Court of Appeals for the Tenth Circuit. After getting sidetracked with a...more

9/30/2015 - Appeals Commerce Clause Department of Revenue Direct Marketing Association Interstate Commerce Permanent Injunctions Reporting Requirements Retailers Sales & Use Tax

Not So Fast: ALAS Fails to Attain Sufficient State Support

At the Multistate Tax Commission (MTC) Executive Committee Meeting in Spokane, Washington, the Arm’s-Length Adjustment Service (ALAS) Advisory Group provided an update on its transfer pricing effort. On May 7, 2015, the...more

8/4/2015 - Multistate Tax Commission Transfer Pricing

MTC Nearing Completion of Model Sourcing Regulation for Services and Intangibles

The Multistate Tax Commission’s (MTC) Annual Conference and Committee Meetings are being held on July 27-30, 2015, in Spokane, Washington. On Tuesday, July 28, 2015, at approximately 1:00 pm PDT (exact time subject to...more

7/28/2015 - Intangible Property Leases Market Based Approach Model Rules Multistate Tax Commission Multistate Tax Compact Professional Conferences Real Estate Transactions Services Tangible Property

Taxpayer Wynne’s: Supreme Court Rules Maryland Personal Income Tax Violates Constitution

This morning the U.S. Supreme Court ruled that Maryland’s personal income tax regime is unconstitutional. By failing to provide a full credit to its residents for taxes paid to other states, Maryland unconstitutionally...more

5/19/2015 - Comptroller of the Treasury v Wynne Dormant Commerce Clause Income Taxes Non-Resident Income Taxes SCOTUS

Wynne Court Holds That Internal Consistency Lives, Applies to Taxation of Resident

A divided U.S. Supreme Court ruled that Maryland’s personal income tax regime is unconstitutional. Comptroller of the Treasury v. Wynne, 575 U.S. __ (2015). The Court affirmed the Maryland Court of Appeals in a 5-4 decision...more

5/19/2015 - Comptroller of the Treasury v Wynne Dormant Commerce Clause Income Taxes Non-Resident Income Taxes SCOTUS

MTC Launches Transfer Pricing Effort

On June 2, the Arm’s Length Advisory Group (the Group) of the Multistate Tax Commission (MTC) met in St. Louis, Missouri, to begin the process of developing a multistate arm’s length pricing adjustment service. States...more

6/3/2014 - Audits Multistate Tax Compact Transfer Pricing

MTC Executive Committee Advances Significant Part of UDITPA Rewrite

On Thursday, May 8, the Multistate Tax Commission’s (MTC) Executive Committee (Committee) met in Washington, DC. During the meeting the Committee voted to advance its amendments to the Multistate Tax Compact’s (Compact)...more

5/12/2014 - MTC Multistate Tax Compact Proposed Amendments UDITPA

Legal Alert: New York Tax Reform to Impact Captive Insurance Companies

In January, New York Governor Andrew Cuomo proposed broad corporate tax reform in his budget bill, which is currently winding its way through the legislature. The most significant proposal is a shift from a separate entity...more

2/28/2014 - Andrew Cuomo Captive Insurance Company Corporate Taxes State Taxes Tax Reform

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