Tag Archives: Proposed Regs

Filing Season Reminder: Revisions (and Challenges) to Alternative Apportionment Regulation

Any taxpayers considering taking an alternative apportionment position on its corporate excise tax returns this fall should remember that the Department adopted a revised alternative apportionment regulation, 830 CMR 63.42.1, which is applicable to the 2016 tax year. Under the regulation, a taxpayer must file a request for alternative apportionment when it files its tax return.  … Continue Reading

Hearing on August 24 regarding Massachusetts Sales Tax “Cookie” Nexus Draft Regulation for Internet Vendors

Massachusetts is looking to join a growing list of states asserting that internet vendors that lack traditional “physical presence” in a state must still collect sales tax if they have sufficient economic contacts.  But unlike states that have passed “Kill Quill” statutes that challenge Quill directly, Massachusetts takes a more nuanced approach that potentially presents … Continue Reading

Massachusetts Market Sourcing Update: Report from Public Hearing on Market Sourcing and Special Industry Apportionment Regulations

Today, the Department of Revenue held a hearing for the public to present comment regarding the Department’s proposed market sourcing regulation.  In addition, the proposed special industry apportionment regulations for Airline Corporations, Motor Carriers, and Courier and Package Delivery Services; and the proposed corporate nexus regulation were also addressed at today’s hearing.  The proposed regulations were … Continue Reading

Massachusetts Releases Second Draft of Market Sourcing Regulations

This afternoon, the Massachusetts Department of Revenue released its Proposed Regulation 830 CMR 63.38.1: Apportionment of Income, to implement the market-based sourcing rules which took effect for tax years beginning after January 1, 2014.  Here is the proposed market sourcing regulation. The Proposed Regulation follows a Working Draft of the same regulation which was released by the … Continue Reading

Department Extends Comment Period for Proposed Market Sourcing Regulations

The Department of Revenue announced Wednesday that the period for commenting on the proposed market-based sourcing regulations has been extended from May 1 to May 19, 2014.  At the teleseminar held on April 10, Reed Smith discussed several provisions in the proposed regulations worthy of comments.  To view our slide deck from the teleseminar or … Continue Reading

Massachusetts Tax Regulation Changes on the Way—Department of Revenue lays out plans for amended and new regulations for 2014

The Massachusetts Department of Revenue has released its plans for drafting new and amended state tax regulations (as well as a few repeals) for 2014.  Notable planned changes to the Code of Massachusetts Regulations include: Amendments to the NOL deductions and carryforward regulation to reflect changes under combined reporting (830 CMR 63.30.2). Amendments to corporate … Continue Reading