Kyle O. Sollie

Kyle O. Sollie

Reed Smith

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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

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

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