Michael Jacobs

Michael Jacobs

Reed Smith

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Massachusetts Court Issues 'True Debt' Decision

On June 8, the Massachusetts Appeals Court once again denied a taxpayer’s claimed deductions from the income and net worth tax base of the corporate excise tax. In a decision that will be a disappointment for taxpayers...more

6/10/2016 - Audits Corporate Taxes Cross-Border Transactions Debt Department of Revenue Excise Tax Intercompany Transactions IRS Statements of Net Worth Tax Deductions Taxable Income

Massachusetts Net Worth “True Debt” Litigation Moves Forward—Oral Argument Held, Awaiting Decision

With oral argument and briefing complete, the Massachusetts Department of Revenue’s authority to increase the net worth component of a taxpayer’s corporate excise using its “true debt” analysis is under review by the Appeals...more

3/4/2016 - Appeals Corporate Taxes Debt Excise Tax Income Taxes International Finance Statements of Net Worth

Massachusetts Denies ‘True Debt’ Treatment for Cash Management Obligations

The Massachusetts Appellate Tax Board (“ATB”) has once again issued a Findings of Fact and Report upholding a Department assessment on the basis that a taxpayer’s intercompany obligations under a cash management system were...more

9/9/2015 - Debt Excise Tax Staples Tax Appeals Tax Deductions

Department of Revenue releases detailed guidance for corporate excise tax amnesty program

The Massachusetts Department of Revenue released TIR 15-2 specifying the administrative details of the amnesty program authorized by the legislature earlier this year. The amnesty period is open now through May 15, 2015, for...more

3/24/2015 - Corporate Taxes Department of Revenue Excise Tax Tax Amnesty

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 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

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 Sales & Use Tax

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