The Massachusetts Supreme Judicial Court recently held that software vendors have a statutory right to apportion tax on the sale of prewritten computer software purchased for use in multiple states and that they may do so through the Commonwealth’s general tax abatement process. The court’s decision in Oracle USA, Inc. v. Commissioner of Revenue, 487 Mass. 518 (2021) confirms that the ability to apportion tax on software is not contingent on strict compliance with the administrative procedures set forth in the Massachusetts Commissioner of Revenue’s apportionment regulation. The tax abatement process is an acceptable mechanism for taxpayers to seek tax apportionment with respect to software purchased for use in multiple jurisdictions. Continue Reading ›
On May 25, the U.S. Solicitor General filed its highly anticipated brief in New Hampshire v. Massachusetts and recommended that the Court decline jurisdiction over the case. Although the ultimate decision is yet to be issued, the U.S. Supreme Court generally follows the Solicitor General’s recommendations after, as here, the Court requests the U.S. government’s input.
Pillsbury SALT is pleased to welcome Jeff Phang to the team!
Jeff focuses primarily on tax controversy including voluntary disclosure agreements, audit defense, protest, settlement negotiation, and appeals proceedings. Jeff also advises on mergers and acquisition state and local tax diligence for a diverse range of businesses.
He will join Pillsbury’s Sacramento office as an associate.
Pillsbury SALT is pleased to welcome Lexi Louderback to the team!
Lexi’s experience includes state and local tax matters, focusing on tax controversy, from audit defense through litigation, and counsels on multistate tax planning and structuring matters.
She joins Pillsbury’s Sacramento office as an associate.