I Have a (Tax) Plan for That: The Imminent Return of Multistate Tax Planning

The days of naked Delaware holding companies and royalties paid for giraffes named Geoffrey may be long gone but, thanks to the Tax Cuts and Jobs Act of 2017, multistate tax planning is back on the minds of corporate CFOs.  During the 1990s, variations in the tax laws and policies among states imposing corporate income taxes inspired practitioners to present a smorgasbord of plans to restructure multistate organizations with the intent of exploiting these differences...

Public Law 86-272, We Hardly Knew Ye

"Ye're an armless, boneless, chicken-less egg You'll have to be left with a bowl out to beg Oh Johnny I hardly knew ye. . ."  You would know the tune to these lyrics to Oh Johnny I Hardly Knew Ye from its later appropriation for When Johnny Comes Marching Home Again.  In the original 1867 song penned by English music hall notable Joseph B. Geoghegan, the protagonist went off to war. There, he proceeded to lose limbs—arms, legs, and in some versions, even eyes! That...

Think You’re Not a Manufacturing Company? Think Again!

Deadline Approaching for 2018 Retroactive Classification in Massachusetts Like many states, Massachusetts offers significant tax benefits to corporations engaged in manufacturing. But, what is “manufacturing?” In the words of a former U.S. president, “it depends on what the meaning of the word ‘is’ is.” Or, in this case, the meaning of “manufacturing.” The window will soon close for classification as a manufacturing corporation for the 2018 calendar year. Now is the time to consider whether your company...