News & Analysis as of

Apportionment Tax Refunds

Cadwalader, Wickersham & Taft LLP

Is There Taxation Without Realization? Moore May Create More Questions Than Answers

The U.S. tax system developed in response to colonial opposition to taxation without representation.  As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more

Holland & Knight LLP

Texas Franchise Taxpayers May Need to Consider Filing Protective Refund Claims

Holland & Knight LLP on

The issue of whether receipts from the sale of securities should be included in the franchise tax apportionment factor on a gross or net basis may be heard by the Texas Supreme Court after all. There are two cases, Citgo...more

McDermott Will & Emery

Massachusetts Supreme Judicial Court Approves Sales Tax Apportionment for Software

McDermott Will & Emery on

On May 21, 2021, the Massachusetts Supreme Judicial Court issued a decision affirming the Massachusetts Tax Appeal Board’s decision in favor of Microsoft and Oracle, ruling that the companies may apportion sales tax to other...more

Eversheds Sutherland (US) LLP

Court of Appeals Hears Michigan’s Compact Election Cases

The long saga of Michigan's Multistate Tax Compact election continued on Wednesday with oral argument before the Michigan Court of Appeals. A packed courtroom witnessed a 1.5 hour proceeding before an active three-judge...more

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