Richard Call

Richard Call

Morrison & Foerster LLP

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State + Local Tax Insights -- Spring 2014

In This Issue: - Where’s Walden? Finding Protection under the Due Process Clause - Upcoming Speaking Engagements - CFCs and Subpart F Income in a California Water’s-Edge Election and What’s Wrong with the Apple...more

4/17/2014 - Apple CFCs Due Process Franchise Tax Board Franchise Taxes SALT State Taxes Subpart F

State + Local Tax Insights -- Winter 2014

In This Issue: Ringing in the New Year: Issues from 2013 That Will Likely Impact 2014; Upcoming Speaking Engagements; Defending Against Penalties; and Dueling “Doing Business” Interstate-Commerce Exemptions:...more

1/15/2014 - Internet Taxation Interstate Commerce Penalties SALT State Taxes Tax Reform

State + Local Tax Insights -- Fall 2013

In This Issue: “Occasional Sales” and Single Sales Factor Apportionment in California; Upcoming Speaking Engagements; State Taxation of Financial Institutions; Applying the True Object Test to Determine the Taxability...more

10/29/2013 - Apportionment Economic Presence Nexus Franchise Taxes SALT State Taxes

Economic Nexus Curtailed, Again

Introduction - In a period of 18 months, three state courts have refused to extend economic nexus approaches to the facts before them, despite prior decisions in those states that corporations without physical presence...more

10/21/2013 - Corporate Taxes Nexus

‘Inherited’ Nexus And Other Extreme Nexus Theories

Nexus — whether a corporation has a sufficient connection such that it may be taxed by a state — is one of the most important issues in state tax. Various legal theories have been asserted (and are being asserted) to justify...more

7/15/2013 - Business Taxes Corporate Taxes Due Process Jurisdiction Nexus Sufficient Nexus

State and Local Tax Insights -- Winter 2013

In This Issue: Sales Tax Nexus Developments in California and Beyond: A Year in Review; Upcoming 2013 Speaking Engagements; Recent MoFo State + Local Taxpayer Victories; Exploring the Subject to Tax Exception to Addback...more

1/24/2013 - Amazon Internet Internet Retailers Sales & Use Tax

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