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Richard C. Call Morrison & Foerster LLP

Results 1 to 5 of 7



Exploring the subject to tax exception to addback statutes *

USA - January 22 2013
Statutes requiring taxpayers to add back royalties or interest paid to related members have been around for two decades and have now been adopted by…

Co-authors: Craig B. Fields.


The due process clause as a bar to state tax nexus *

USA - November 5 2012
In May of this year, the Oklahoma and West Virginia Supreme Courts held that Due Process bars the imposition of a state tax on a company.

Co-authors: Paul H. Frankel, Craig B. Fields.


State tax issues in mergers, acquisitions and restructurings: food for thought *

USA - November 5 2012
Business mergers, acquisitions and restructurings involve legal, regulatory and tax components.

Co-authors: Mitchell A. Newmark.


The unitary business principle applies to more than corporate net income taxes: Reynolds Metals Company v. Department of Treasury *

USA - July 16 2012
Recently, in Reynolds Metals Company v. Department of Treasury, the Michigan Court of Appeals held that the unitary business principle applies to Michigan’s Single Business Tax (the “SBT”).

Co-authors: Paul H. Frankel, Michael A. Pearl, Craig B. Fields.


State taxation of multinational businesses *

USA - July 16 2012
Multinational businesses face a variety of state tax issues.

Co-authors: Craig B. Fields.


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