State Taxes, Amicus Briefs

New York’s Convenience of the Employer Rule – New Jersey and Connecticut Respond

Rivkin Radler LLP on 3/1/2023

History is replete with examples of leaders who chose to battle, or who were forced into defending against, enemies on two fronts. Rarely did it end well for the combatant that occupied the middle ground. In a sense, New...more

Full Speed Ahead: Competing Amicus Briefs in the VAS Holdings Case

Bradley Arant Boult Cummings LLP on 1/31/2022

Is the unitary business principle the sole test for determining whether a state can tax an apportioned share of a non-domiciliary’s capital gains under the U.S. Supreme Court’s Due Process Clause and Commerce Clause...more

Grasping at Straws: The Amicus Brief of the United States in New Hampshire v. Massachusetts

Blank Rome LLP on 6/17/2021

Last October, New Hampshire filed a challenge with the U.S. Supreme Court condemning Massachusetts’s temporary rule requiring nonresident employees of Massachusetts’s employers to continue sourcing income to Massachusetts,...more

State Taxation Of Telecommuting Employees And Their Nonresident Employers

Farrell Fritz, P.C. on 12/28/2020

Mending Walls- “Good fences make good neighbors,” or so Robert Frost’s neighbor from “beyond the hill” says to him when “on a day” they “meet to walk the line and set the wall between” them “once again.” The neighbor...more

Eversheds Sutherland files amicus curiae brief on behalf of COST in Fresno Measure P case

Eversheds Sutherland (US) LLP on 9/14/2020

Eversheds Sutherland has filed an amicus curiae brief on behalf of the 550 members of the Council On State Taxation (COST) on the important issue of whether imposition of certain local special taxes in California requires a...more

How Far Back Can a Back Tax Go? Petition for Certiorari in Hambleton Asks Supreme Court to Right Unjust Retroactivity

McDermott Will & Emery on 7/15/2015

Retroactivity is an endemic problem in the state tax world. In this year alone, we have seen retroactive repeal of the Multistate Tax Compact (MTC) in Michigan, as well as significant retroactivity issues in New York, New...more