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Massachusetts SJC Reaffirms Decision Sourcing 100% of Taxpayer’s Loans to Massachusetts — Confirms Opportunity for Out-of-State Financial Institutions

On Friday, August 12, the Massachusetts Supreme Judicial Court (the “SJC”) reaffirmed its decision in First Marblehead—that a financial institution that is commercially domiciled in Massachusetts can be required to source 100% of its loans to Massachusetts for purposes of computing its property factor numerator.  See The First Marblehead Corp. v. Commissioner, Supreme Judicial Court … Continue Reading

First Marblehead Requests U.S. Supreme Court Review In SINAA Sourcing Appeal

In a case of interest for any taxpayer with substantial securitization activities, First Marblehead Corporation and Gate Holdings, Inc. have requested United State Supreme Court review of a recent determination of the Massachusetts Supreme Judicial Court (“SJC”), by way of this petition. The petition for review can be found here. The case involves the sourcing … Continue Reading

Reminder for Taxpayers to File Refunds for the Defunct Massachusetts “Tech Tax”

For nearly 220 vendors, time is running out to file applications for abatement to obtain refunds of the nearly $800,000 in taxes paid to the Department of Revenue under the repealed sales tax on software services.  According to a recent blog post by the Department, although approximately 250 vendors collected the tax from customers and … Continue Reading
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