Michael Jacobs

Michael Jacobs

Reed Smith

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Pennsylvania DOR Releases Draft Market-Sourcing Guidelines

On June 16, the Department of Revenue released draft guidance on applying Pennsylvania’s new market-based, sales factor sourcing legislation that was signed into law in July 2013. The new market-sourcing legislation is...more

6/20/2014 - Department of Revenue New Legislation Tax Rates

April Fools? No Joke, Virginia Law Limiting Addback Exceptions To Be Applied Retroactively for 10 Years

On April 1, 2014, Virginia Governor Terry McAuliffe signed HB 5001. This law imposes severe restrictions on the existing exceptions to intangible expense addback to Virginia taxable income. Specifically, the new law limits...more

4/4/2014 - Income Taxes Royalties

Massachusetts Tax Developments - A Reed Smith Quarterly Update (4th Quarter 2013)

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll take a look back to the developments from the last quarter of 2013, and look ahead to some percolating issues at the Appellate...more

2/13/2014 - Cloud Computing Corporate Taxes Sales & Use Tax SALT State Taxes

Virginia Adopts Narrow Definition of “Royalty” for Purposes of its Intangible Expense Add-Back

In a recent ruling, the Virginia Department of Taxation determined that payments made by a taxpayer to an affiliated corporation were not "royalty" payments and should not have been added back to the taxpayer’s Virginia...more

12/17/2013 - Income Taxes Royalties

Massachusetts Tax Developments - A Reed Smith Quarterly Update (3rd Quarter 2013)

Welcome to the Reed Smith Massachusetts State Tax Quarterly Update for the 3rd Quarter of 2013. This update includes coverage of the repeal of the short-lived software services tax and pending litigation on other...more

10/17/2013 - Corporate Taxes Excise Tax Interest Rates Royalties State Taxes Transfer Taxes

Massachusetts Delays Reporting for Software Services Tax; Repeal Imminent?

With the drumbeat for repeal of the new software services tax growing louder, the Massachusetts Department of Revenue today pushed back the date for reporting and remitting sales and use tax collected or accrued on sales...more

9/17/2013 - Department of Revenue Reporting Requirements Sales & Use Tax Software

Massachusetts Rules Against Taxpayer on Treatment of Intercompany Debt—Again

In what is becoming a trend, the Massachusetts Appellate Tax Board (the "ATB") has issued yet another decision denying true debt treatment for an intercompany obligation. In National Grid Holdings, the ATB upheld assessments...more

9/9/2013 - Corporate Taxes Debt Excise Tax IRS SEC Statements of Net Worth UK

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

Welcome to the latest Massachusetts Quarterly Update from Reed Smith. This update for the 2nd Quarter of 2013 includes coverage of a number of corporate excise tax developments, in particular: (i) pending apportionment...more

7/18/2013 - Bad Debt Compliance Corporate Taxes Debt Nexus Proposed Legislation SINAA Test Tax Rates

Massachusetts Department of Revenue and Appellate Tax Board Look to Expand Tax Dispute Mediation Programs

The Massachusetts Department of Revenue has indicated it is looking to expand taxpayer eligibility for its early mediation program for expedited settlement of tax disputes by including taxpayers with smaller proposed tax...more

6/24/2013 - Department of Revenue Eligibility Mediation Settlement Tax Assessment

Virginia Court Denies Best Buy’s Bad Debt Credit, Leaves Hope for Other Retailers

A Virginia circuit court recently held that Best Buy was not entitled to a refund of sales tax remitted to the Virginia Department of Taxation on certain credit card sales....more

5/31/2013 - Bad Debt Best Buy Credit Cards Default Financing Retailers Sales & Use Tax

South Carolina Supreme Court (Reluctantly) Upholds Sales Tax Exemptions

Yesterday, the South Carolina Supreme Court issued its long-awaited decision in Bodman v. South Carolina, holding that the state’s sales and use tax exemption and cap scheme, as a whole, does not violate the state...more

5/13/2013 - Equal Protection Sales & Use Tax Tax Exemptions

Massachusetts Tax Developments - A Reed Smith Quarterly Update (1st Quarter 2013)

The first quarter of 2013 saw Massachusetts developments for some the biggest tax issues facing the state, including taxation and sourcing of cloud computing, SaaS and other web-based software products and services;...more

4/26/2013

Pennsylvania Tax Developments

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

4/24/2013 - Amended Legislation Compliance Gross Receipts Tax Market Based Approach Sales & Use Tax Settlement

Software Vendor Challenges Massachusetts’ Restrictive Policy on Multiple Points of Use Certificates

Software purchasers that have paid Massachusetts sales tax on the full purchase price for software that was also concurrently available for use by employees outside Massachusetts, should consider filing protective refund...more

4/15/2013

Connecticut Governor Proposes Tax Amnesty for Fall 2013 – Will It Be Worth the Wait?

In January, Connecticut Governor Dan Malloy introduced S.B. 843, which includes a number of revenue items that are part of the governor’s 2014-2015 biennial state budget. Among the revenue items included in the bill is a tax...more

3/20/2013 - State Budgets Tax Amnesty

Opportunities for Real Estate Transfer Tax Refunds in Pennsylvania

Taxpayers that paid Pennsylvania or Philadelphia real estate transfer tax on certain transactions involving real property located in Philadelphia during the period July 1, 2012 through January 5, 2012 may be entitled to...more

2/5/2013 - Income Taxes Real Estate Market Realty Transfer Taxes Refunds

Reed Smith Massachusetts Quarterly Update - 4th Quarter 2012

Welcome to the first of a new series of quarterly updates from Reed Smith on state tax developments in Massachusetts. Every three months we will be updating you on the key cases and administrative releases, as well as...more

1/21/2013 - Amazon Appeals Audits Commerce Clause Debt Due Process Excise Tax Interest Payments Manufacturers Mediation Operation Test Sales & Use Tax

Disk or No Disk – Cloud Computing Services Not Taxable In Virginia

If you are located in Virginia and use a cloud computing service, and you (or your cloud provider) received a disk, manual, or other incidental tangible property in connection with your purchase of the service, you may have...more

1/14/2013 - Cloud Computing Sales & Use Tax Software Tangible Property

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