Kyle O. Sollie

Kyle O. Sollie

Reed Smith

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Court Hears Oral Argument in New Jersey Partnership Nexus Case: Tough Questions for Division of Taxation

Earlier this week, a New Jersey appellate court heard oral argument in BIS LP, Inc. v. Director, Div. of Taxation, which is the lead case addressing the issue of whether a corporate limited partner is taxable on its...more

3/10/2014 - Business Taxes Corporate Taxes Limited Partnerships Nexus Partnerships

Division Avoids Another Throwout Defeat, But Puts Economic Nexus at Risk

Earlier this week, the New Jersey Tax Court released a letter opinion in Whirlpool Properties Inc. v. Director, its latest decision involving throwout. The Division of Taxation had argued that there were unresolved factual...more

11/4/2013 - Corporate Taxes Economic Presence Nexus Income Taxes Intangible Holding Company Royalties Settlement State Taxes Trademarks

FTB to Clean Up Deferred Intercompany Stock Account Regulation

On July 25, the FTB held a public hearing on its proposed revisions to its regulation on intercompany transactions. The changes attempt to fix issues with the current rules governing Deferred Intercompany Stock Accounts...more

8/2/2013 - Corporate Contributions Franchise Tax Board Liquidation Mergers Proposed Regulation Stock Options

Pennsylvania Tax Developments - A Reed Smith Quarterly Update (2nd Quarter 2013)

This is a brief update on recent Pennsylvania tax developments. It is intended to provide an overview of issues and cases to watch, as well as administrative and legislative developments....more

7/31/2013 - Franchise Taxes Income Taxes Net Operating Losses Tax Reform

California Quarterly Update -- A Reed Smith Quarterly Update (2nd Quarter 2013)

Welcome to the first edition of a series of quarterly updates from Reed Smith on California state tax developments. Every quarter, we will bring you legal updates and provide some insight on what taxpayers are facing in...more

7/30/2013 - Attorney's Fees Enterprise Zones Jerry Brown Multistate Tax Compact New Legislation Tax Incentives

Major PA Tax Bill Passes: Franchise Tax is Back! Market Sourcing has Arrived; Addbacks Too

After months of negotiations and bargaining surrounding Pennsylvania’s budget, the House and Senate passed major tax code changes Tuesday (in House Bill 465). The bill is now on its way to Governor Corbett’s desk for...more

7/5/2013 - Franchise Taxes New Legislation State Taxes

California Court Finds Securitization Entities Subject to California Income Tax

A California Superior Court has issued a decision with significant impact on financial services. In the case, Harley-Davidson, Inc. v. Franchise Tax Board, San Diego Superior Court Judge Joel Pressman held that...more

5/13/2013 - Harley-Davidson Income Taxes Securitization SPEs

Market Sourcing Comes to New Jersey … Or Not

Later this month, the New Jersey Division of Taxation is expected to propose a regulation that will adopt a market-based approach to source receipts from services. On the surface, it appears difficult to reconcile the...more

4/9/2013 - Market Based Approach Net Operating Losses Proposed Regulation State Taxes

California’s Attempt to Retroactively Tax its Residents

In Cutler v. Franchise Tax Board, a case litigated by Reed Smith, a California Court of Appeal held that the California property and payroll requirements of California’s Qualified Small Business Stock provisions were invalid....more

2/12/2013 - Capital Gains Commerce Clause Cutler v Franchise Tax Board Franchise Tax Board Investors Qualified Small Business Stock Retroactive Application Retroactive Taxes Startups Tax Deferral

Microsoft Court Holds Right to Replicate Software Is an Intangible Property Right for Purposes of California’s Sales Factor...

Earlier this week, the California Court of Appeal, First District, held that the right to replicate and install software is an intangible property right for sales-factor sourcing purposes. Thus, for the years at issue, the...more

12/28/2012 - Franchise Tax Board Intangible Property License Agreements Microsoft Right to Replicate Royalties Software Tangible Property

California’s Proposition 39: Not-so-Mandatory Single Sales Factor

On November 6, California voters passed Proposition 39, which changes the state’s default apportionment to a single sales factor method. Additionally, Proposition 39 adopted a mandatory market-sourcing method for sourcing...more

11/14/2012 - Franchise Tax Board Gillette v Franchise Tax Board Multistate Tax Compact Proposition 39 Sales Factor

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