Recent State and Local Tax Controversies
- Representation of a fuel oil company in Illinois local sales tax sourcing litigation.
- Representation of a major airline in Illinois local sales tax sourcing litigation.
- Representation of a major retailer in Illinois local sales tax sourcing litigation.
- Representation of 9 retailers in Illinois sales tax whistleblower litigation.
- Representation of a telecommunications carrier in Illinois sales and telecommunications tax whistleblower litigation.
- Representation of a major wireless carrier in business/nonbusiness income disputes in multiple states.
- Representation of a major wireless carrier in sales tax disputes in multiple states.
- Representation of a major wireless carrier in Missouri local license tax litigation.
- Representation of an electric utility in defense of municipal electricity tax assessments by two dozen municipalities.
- Representation of a major manufacturer in an Illinois case involving business/nonbusiness income and the proper identification of a unitary business group.
- Representation of a major railroad in cases in multiple jurisdictions involving business/ nonbusiness income and the composition of the unitary business group.
- Representation of a major retailer in a case involving the availability of the Illinois investment credit for property used in retailing.
- Representation of a major media company in computing its Illinois franchise tax following a merger.
- Representation of a major manufacturer in filing a petition for a writ of certiorari to the Supreme Court of Alabama regarding the constitutionality of the disallowance of certain intercompany expenses.
- Representation of a major manufacturer in filing a petition for a writ of certiorari to the Alabama Court of Civil Appeals regarding the constitutionality of the state’s treatment of the sale of certain in-state properties as nonbusiness income.
- Representation of a hedge fund manager in an Illinois dispute as to the deductibility of a reasonable allowance for compensation paid or accrued for services rendered by partners to the partnership.
- Representation of a fund-of-funds in a California tax sourcing dispute.
- Representation of an investment advisor regarding the retroactivity of amendments to California’s tax penalty regime.
- Representation of a hotel chain in defense of a real property transfer tax assessment by the City of Oakland, California.
- Representation of a major league sports team in defense of an assessment of Cook County Amusement Tax.
- Representation of an online ticket reseller against an assessment of Chicago Amusement Tax.
- Representation of a wireless carrier in defense of a Chicago telecommunications tax.
- Representation of a medical device manufacturer against a Tennessee sales tax assessment.
- Representation of a major hospital chain in defense of an Illinois income tax assessment based upon the composition of the unitary business group.
- Representation of an automobile finance company, automobile leasing company, consumer lender, and mortgage company in receipts-factor sourcing and property-factor measurement litigation in Louisiana state court.
- Representation of a credit card issuer in its defense against receipts-factor sourcing assessments before the Washington Department of Revenue.
- Representation of a credit card issuer in its defense against receipts-factor throw-out assessments in New Jersey state court.
- Representation of a credit card issuer in receipts-factor sourcing refund claims in New Jersey state court.
- Representation of a broker-dealer in a receipts-factor assessment that became a refund claim before the New York State Division of Tax Appeals and the New York State Supreme Court.
- Representation of a seller of a hotel in a sales tax collection assessment relating to abandoned furniture, fixtures, and equipment before the New York State Division of Tax Appeals.
- Representation of a credit card issuer in its defense against receipts-factor assessments before the North Carolina Department of Revenue.
- Representation of an investment fund in claiming an exemption from the New York City unincorporated business tax for distressed debt investing activities before the New York City tax appeals tribunal.
- Representation of a consulting services provider in the prosecution of a refund claim and defense against assessments arising from a receipts-factor sourcing dispute before the New York City tax appeals tribunal.
- Representation of a privately held wholesale cigar distributor against tobacco tax collection liability assessments in New Jersey state court, before the New Hampshire Department of Revenue Administration, and the Maryland comptroller.
- Representation of an individual against a use tax assessment on private aircraft before the California Board of Equalization.
- Representation of a holding company against a use tax assessment on private aircraft before the Pennsylvania Board of Finance and Revenue.
- Representation of a holding company in a claim for refunds arising from federal changes before the Pennsylvania Board of Finance and Revenue and in Pennsylvania state court.
- Representation of an international sports association against local business activity tax and use tax assessments in numerous jurisdictions.
- Representation of a foreign government in defending against taxability before the Texas comptroller.