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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

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

Massachusetts Tax Developments - A Reed Smith Quarterly Update: June 2015

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look at the most recent developments in Massachusetts corporate tax, provide some administrative updates, and discuss some hot...more

Appellate Tax Board Case Update: MassMutual Proves Intercompany Debt is True Debt

Today, the Appellate Tax Board (“ATB”) released its Findings of Fact and Report in the related cases of Massachusetts Mutual Life Insurance Company and MassMutual Holding LLC v. Commissioner and MML Investor Services, Inc. v....more

First Marblehead Requests U.S. Supreme Court Review In SINAA Sourcing Appeal

In a case of interest for any taxpayer with substantial securitization activities, First Marblehead Corporation and Gate Holdings, Inc. have requested United State Supreme Court review of a recent determination of the...more

Massachusetts Tax Developments - A Reed Smith Quarterly Update: March 2015

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look at the most recent developments in Massachusetts corporate tax, sales and use tax, and tax administration; and discuss some...more

Massachusetts Tax Developments: A Reed Smith Quarterly Update (3rd Quarter 2014)

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look back to the developments from the first half of 2014, and look ahead to market-based sourcing and other issues on the...more

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

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

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

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

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