On October 31, 2014, the Massachusetts Taxpayers Foundation put on their annual tax conference with panels comprised of a mix of tax practitioners and government officials covering the latest issues in Massachusetts taxes.  As always, the conference provided great content and an opportunity for taxpayers, practitioners and government officials to get up-to-speed on the latest in Massachusetts state and local taxes.

As we noted in our prior post, the Department chose the night before the conference for the release of revised draft market sourcing, special industry apportionment regulations, and corporate nexus regulations; changes that were the topic of the day among conference attendees.  The timing was perfect for a panel including Kevin Brown and Rebecca Forter of the Department of Revenue who both provided great insights into the market sourcing regulations and what the Department hoped to achieve with the proposed revisions.

Other highlights included:

  • Commissioner Pitter’s update on Department priorities, including the latest on Department’s mediation program.  The Department has now mediated fourteen cases as part of its mediation program, with eleven of those cases resulting in a successful settlement.  Four more mediations are now in the pipeline.  Click here for Reed Smith’s update on the Department’s mediation initiative; and click the following link for slides from Reed Smith’s presentation on national mediation programs discussing our insights from participating in the program: Mediation Presentation.
  • Updates regarding recently decided Massachusetts tax litigation, including a discussion of a recent Appellate Tax Board decision (with Findings of Fact and Report yet to be published) where the Department reclassified a taxpayer’s obligations to an affiliate under a cash management system as equity, and thus, denied an interest deduction for its payments to its affiliate.  For more detail on this issue, check out our prior alert.

Thanks to MTF for putting on a great conference.  We here at Reed Smith are looking forward to 2015!