Double Taxation Apportionment

News & Analysis as of

Wynne’s First Casualty: First Marblehead Corp. v. Commissioner

Today, the U.S. Supreme Court vacated the decision of the Massachusetts Supreme Judicial Court (SJC) in First Marblehead Corp. v. Commissioner of Revenue (First Marblehead) and remanded the case back to the court for...more

Can Taxpayers Find an Advantage in Vodafone Nowhere Income Argument?

It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more

PA Supreme Court Issues Business / Nonbusiness Income Decision

The Pennsylvania Supreme Court has held that a taxpayer’s gain from the sale of timberland was apportionable business income using the “functional test” of Pennsylvania’s amended definition of “business income.” Glatfelter...more

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