January 2014

We can’t resist man’s best friend, and four handsome hounds caught our eye…Layla, Romeo, Gracie and Rocky.

Pet 1 - Wechman.jpgMeet Layla, also known as Lei-Lei, the 18-month-old companion of Craig Wechman (State Tax Director, Royal Bank of Canada), his wife Trish, and their kids Dylan and Lauren. The family went apple picking in Pennsylvania in October 2012

By Jessica Kerner and Timothy Gustafson

The Indiana Department of Revenue determined that the storage of advertising catalogs in Indiana, for a taxpayer’s out-of-state clients, did not create sales tax nexus for such clients. The taxpayer stored the catalogs at its facilities in Indiana prior to distributing the catalogs to recipients throughout the United States.

By Sahang-Hee Hahn and Andrew Appleby

The California Franchise Tax Board amended its regulation governing the sourcing of sales of tangible personal property to reflect California’s statutory shift in 2009 to the Finnigan rule, effective for tax years beginning on or after January 1, 2011. As amended, the regulation assigns receipts from sales of tangible

By Nicole Boutros and Timothy Gustafson

The New York State Department of Taxation and Finance issued an advisory opinion determining that a securities broker may source receipts from “matched principal transactions” based on the “production credit method” provided in New York tax law. The taxpayer was a U.S. entity operating in six states, including New

By Kathryn Pittman and Timothy Gustafson

The Virginia Tax Commissioner ruled a taxpayer’s licensing arrangements with a subsidiary intangible holding company (IHC) did not meet the unrelated party exception to Virginia’s intangible expense add-back statute. The taxpayer, a national operator and franchisor of fast food restaurants, created the IHC to hold its intangible property

By Scott Booth and Andrew Appleby

The Massachusetts Governor released his proposed fiscal year 2015 budget, which includes a tax provision that is targeted directly at the insurance industry. Currently, income earned by pass-through entities, such as partnerships, owned by licensed life or property and casualty insurers is excluded from Massachusetts income tax because