Direct Taxes

Income Tax


  • Analysis of the safe harbor provisions of P.L. 86-272, including the analysis of the use of independent contractors; third party representatives; limitations of protected activities and the definition of delivery
  • Constitutional protections including: economic nexus and factor presence nexus; flash nexus
  • Individual residency issues
  • Trust residency issues


  • Analyzing the complex issues that result from the sourcing of services and intangible income including the application of cost of performance methods and market based sourcing;
  • Developing alternative methods of apportionment to address distortive results statutory formulas
  • Unitary business issues including: defining the composition of the group; instant unity; worldwide combination issues
  • Addressing the application of throwback including the Joyce v. Finnigan rules

Tax Base

  • Application of expense add-back statutes to both domestic and foreign operations
  • Addressing transfer pricing adjustments and forced combination issues
  • Challenging the issues surrounding the characterization of income that arise as a result of liquidation of line of business; gains on sale of appreciated securities or flow through interests; sale of non-unitary divisions or investments
  • Treatment of corporate owned flow-through entities;
  • Taxation of captive insurance companies
  • Taxation of captive REITS
  • Utilization of net operating losses and capital losses
  • Characterization of foreign taxes
  • Taxation of foreign source income and tax havens


  • Statute of limitation issues
  • Reporting of federal audit adjustments
  • Voluntary Disclosure Agreements
  • Penalty Issues
  • Massachusetts Mediation Program
  • California Settlement Bureau


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