Insights & Developments


State Tax

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March  19, 2010 - Weekly State Tax Report
Protective Privileges, Uncertain Tax Disputes, and Beyond: Why the U.S. Supreme Court Should Grant Review in Textron

In a closely watched case, Textron Inc. has asked the U.S. Supreme Court to review a decision of the U.S. Court of Appeals for the First Circuit that dramatically narrowed the traditional scope of protection afforded under the “work-product privilege.” The First Circuit's decision, if allowed to stand, has significant implications for tax practitioners and their corporate clients, both in the federal and state arenas. In this article, authors Donald M. Griswold, Donna M. Doblick, and Sara A. Lima, discuss the limitations of work-product privilege in different contexts and why the U.S. Supreme Court should grant review. 

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March  12, 2010 - Weekly State Tax Report
Revenue Agent's Reports: The State Side of Federal Adjustments Can Raise Thorny Compliance Issues for Multistate Corporations
When taxpayers are subject to multiyear examinations by the Internal Revenue Service, they face more than the potential for federal tax assessments. Very often, even when taxpayers reach a settlement with the IRS, they must deal with a complex and arduous compliance burden at the state level. In this article, the authors review the contradictory state requirements for filing amended returns or notifying state taxing authorities following adjustments to federal taxes.

 

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March  05, 2010 - Weekly State Tax Report
Deal Break-Up Fees and Joint Ventures: Comcast's California Appeal Presents Interesting Issues to Watch

Comcast Cablevision is challenging a California assessment based on the state's treatment of a “break-up fee” by a would-be acquisition as business income and its contention that the taxpayer's 57 percent interest in a home shopping network renders it unitary with the TV retailer. In this article, Kyle O. Sollie and Brian W. Toman, of Reed Smith LLP, review Comcast's arguments and the lessons other taxpayers might draw from the case.

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