Tag Archives: Internal Consistency

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

Supreme Judicial Court Rules Against Taxpayer in Regency Transportation

On January 6, the Massachusetts Supreme Judicial Court (“SJC”) issued its decision in Regency Transportation v. Commonwealth, finding against the taxpayer.  The taxpayer in Regency was a trucking company that purchased vehicles in states that did not charge sales tax on the purchases.  Regency used the vehicles more than half the time outside of Massachusetts … Continue Reading
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