California court finds securitization entities subject to California income tax *

USA - May 13 2013
A California Superior Court has issued a decision with significant impact on financial services. In the case, Harley-Davidson, Inc. v. Franchise Tax…

Co-authors: Marty Dakessian, Mike Shaikh.

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Market sourcing comes to New Jersey … or not *

Jersey, USA - April 8 2013
Later this month, the New Jersey Division of Taxation is expected to propose a regulation that will adopt a market-based approach to source receipts…

Co-authors: David J. Gutowski.

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Microsoft court holds right to replicate software is an intangible property right for purposes of California’s sales factor sourcing rules *

USA - December 21 2012
Earlier this week, the California Court of Appeal, First District, held that the right to replicate and install software is an intangible property right…

Co-authors: Marty Dakessian, Mike Shaikh, Brian W. Toman.

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California’s Proposition 39: not-so-mandatory single sales factor *

USA - November 12 2012
On November 6, California voters passed Proposition 39, which changes the state’s default apportionment to a single sales factor method.

Co-authors: Marty Dakessian, Mike Shaikh, Brian W. Toman.

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N.J. courts: no N.J. tax on limited partnerships - or their limited partners *

USA - October 31 2012
If you are a corporate partner whose only connection with New Jersey is an interest in a partnership (and maybe even an LLC), you should file a refund claim as a result of last Friday’s BIS decision.

Co-authors: David J. Gutowski.

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