Morrison & Foerster LLP - State + Local Tax ("SALT") practice

MoFo New York Tax Insights - Volume 7, Issue 2

State Tax Department Releases New Draft Article 9-A Combined Reporting Regulations - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax regulations…more
| Business Organizations, Civil Procedure, Finance & Banking, Taxation

MoFo Tax Talk - Volume 8, No. 4

IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S. tax…more
| Business Organizations, Civil Procedure, Finance & Banking, International Law & Trade, Taxation

MoFo New York Tax Insights - Volume 7, Issue 1, January 2016

The Top 10 New York Tax Highlights of 2015 - This past year turned out to be another eventful one in New York taxation. We continue our tradition and present our list of the Top 10 New York tax highlights of 2015. 1…more
| Business Organizations, Taxation

MoFo New York Tax Insights - Volume 6, Issue 12

NYC Tribunal Rejects Claim That First Amendment Requires Use of Audience Factor for Sourcing Receipts from Credit Ratings - The New York City Tax Appeals Tribunal, reversing an Administrative Law Judge decision, has held…more
| Administrative Law, Business Organizations, Civil Procedure, Labor & Employment Law, Taxation

MoFo New York Tax Insights - Volume 6, Issue 11

Resident Is Not Subject to Use Tax on Yacht Briefly Docked in the State - In Matter of Michael Pellino, DTA No. 825869 (N.Y.S. Div. of Tax App., Oct. 1, 2015), a New York State Administrative Law Judge concluded that two…more
| Administrative Law, Government Contracting, Real Estate - Commercial, Science, Computers, & Technology, Taxation

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m), the…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law, Taxation

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax…more
| Administrative Law, Business Organizations, Civil Procedure, Taxation

MoFo New York Tax Insights - Volume 6, Issue 9

Tribunal Upholds Personal Liability of LLC Members for Sales Tax - The New York State Tax Appeals Tribunal has affirmed the determination of an Administrative Law Judge that a member of a limited liability company (“LLC”)…more
| Administrative Law, Taxation

MoFo New York Tax Insights - Volume 6, Issue 8 - August 2015

Court Of Appeals Affirms Revocation Of Tax Exemption For Public Parking Facilities - Reversing a decision by the Appellate Division, the Court of Appeals has held in a 5-2 decision that a charitable organization is not…more
| Civil Procedure, Commercial Law & Contracts, Energy & Utilities, Real Estate - Commercial, Taxation

MoFo Tax Talk - Volume 8, Issue 2

IRS Releases Notices Designating Certain “Basket Contracts” As Listed Transactions And Others As Reportable Transactions Of Interest - On Wednesday, July 8, the IRS released two notices addressing “basket contracts,” which…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law, Taxation

MoFo New York Tax Insights - Volume 6, Issue 7 - July 2015

In This Issue: - Important Changes at NYS and NYC Tax Agencies - Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions - NYC Tribunal…more
| Administrative Law, Constitutional Law, Finance & Banking, Taxation

MoFo New York Tax Insights - Volume 6, Issue 6 - June 2015

In This Issue: - Tribunal Reverses ALJ and Permits Combination Based on Unitary Business and Distortion - “Flat Sum Settlement” with IRS Held Not to Constitute Reportable Federal Change - Tribunal Holds NYS…more
| Taxation

MoFo Tax Talk Volume 8, Issue 1

In This Issue: - IRS Rules Debentures Are Part of Straddle; Interest Non-Deductible - Stock Abandonment Produces Ordinary Loss - Tax Consequences of Negative Interest Rates - Renewed Discussion of a Federal…more
| Business Organizations, Securities Law, Taxation

MoFo New York Tax Insights - Volume 6, Issue 4 - April 2015

In This Issue: - State Tribunal Affirms Decision Imposing Sales Tax on Information Services - Appellate Division Upholds Applicability of Sales Tax to Environmental Testing and Monitoring Services - Bulk…more
| Administrative Law, Civil Procedure, Commercial Law & Contracts, Finance & Banking, Taxation

MoFo New York Tax Insights - Volume 6, Issue 3 - March 2015

In This Issue: - Key Proposals in Governor Cuomo’s 2015-16 Executive Budget - ALJ Holds That Online Reservation Receipts Are Not Sourced to New York - ALJ Rules Taxpayer Is Not Required to Use NOLs in Years…more
| Administrative Law, Civil Procedure, Commercial Law & Contracts, Elections & Politics, Taxation
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Contact

1290 Avenue of the Americas
New York, NY 10104-0050, United States

  • (212) 468-8000
  • (212) 468-7900

Areas of Practice
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