Maria P. Eberle

Maria P. Eberle

McDermott Will & Emery

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Take Two: Massachusetts Department of Revenue Releases Revised Market-Based Sourcing Regulation

Late last week, the Massachusetts Department of Revenue (the Department) released a revised draft regulation on Massachusetts’s new market-based sourcing law. The changes made by the Department to purportedly address...more

11/10/2014 - Corporate Taxes Department of Revenue Market Based Approach

MTC’s Market-Based Sourcing Recommendations for UDITPA: Too Little, Too Late?

Member states of the Multistate Tax Commission (MTC) voted to adopt proposed amendments to Article IV of the Multistate Tax Compact during their annual meeting in late July. The proposed amendments likely to have the most...more

9/4/2014 - Income Taxes Multistate Tax Commission State Taxes UDITPA

New York State Department of Taxation and Finance Releases Guidance on the Taxability of Computer Software

The New York State Department of Taxation and Finance (Department) has just released Tax Bulletin TB-ST-128 (Tax Bulletin), addressing how the state’s sales tax applies to sales of computer software and related services. The...more

8/12/2014 - Software State Taxes Tax Reform

New York Corporate Tax Reform: Benefits (and Burdens?) for Qualified New York Manufacturers

Earlier this year, New York enacted sweeping corporate tax reform that included a number of special benefits for qualified New York manufacturers. (For a discussion of this corporate tax reform, see our Special Report.) ...more

8/8/2014 - Corporate Tax Rates Corporate Taxes Manufacturers Tax Credits Tax Reform

Favorable Ruling: Taxability of HMOs Under New York City General Corporation Tax

A New York City Tax Appeals Tribunal Administrative Law Judge (ALJ) recently ruled in favor of Aetna, Inc. (Aetna) on whether a health maintenance organization (HMO) was “doing an insurance business” in New York State,...more

7/28/2014 - Aetna Corporate Taxes Healthcare HMOs

New York’s Revised Nonresident Audit Guidelines: A Tool for Taxpayers?

On June 18, 2014, the New York State Department of Taxation and Finance (Department) published a revised version of its Nonresident Audit Guidelines (Audit Guidelines). The Audit Guidelines are (and have been) issued by the...more

7/18/2014 - Audits Income Taxes Residency Status

Division of Tax Appeals Rules Patent License Fees Not Subject to Sales Tax in New York

A New York State Division of Tax Appeals administrative law judge (ALJ) recently ruled in favor of a medical device and technology company on the question of whether patent license fees that the company charged to its...more

6/27/2014 - Patent Infringement Patent Litigation Patents

Inside the New York Budget Bill Part Five: Net Operating Losses and Tax Credits

This is the fifth installment of a series that takes an inside look at the corporate tax reform proposals in Governor Andrew Cuomo’s 2014–15 New York Budget Bill. This proposed reform is sweeping and, if enacted, is likely to...more

3/21/2014 - Net Operating Losses State Budgets State Taxes Tax Credits Tax Reform

Inside the New York Budget Bill Part Four: Nexus

This installment of Inside the New York Budget Bill examines the Budget Bill’s nexus provisions. Although these provisions may have limited impact on current New York taxpayers, they will significantly affect corporations...more

3/14/2014 - Corporate Taxes Franchise Taxes Nexus

Inside the New York Budget Bill Part Three: Apportionment

This is the third installment of a series that takes an inside look at the corporate tax reform proposals in Governor Andrew Cuomo’s 2014–15 New York Budget Bill. This proposed reform is sweeping and, if enacted, is likely to...more

3/7/2014 - Apportionment State Budgets State Taxes

Inside the New York Budget Bill Part Two: Tax Base and Income Classification

This is the second installment of a series that takes an inside look at the corporate tax reform proposals in Governor Andrew Cuomo’s 2014–15 New York Budget Bill. This proposed reform is sweeping and, if enacted, is likely...more

2/27/2014 - Income Taxes State Budgets

Inside the New York Budget Bill Part One: Combined Reporting

This is the first installment of a series that takes an inside look at the corporate tax reform proposals in Governor Andrew Cuomo’s 2014–15 New York Budget Bill. This proposed reform is sweeping and, if enacted, is likely...more

2/20/2014 - Andrew Cuomo Corporate Taxes State Budgets State Taxes Tax Reform

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