Sectors
Foley & Lardner LLP partner Lynn Gandhi was featured in a recent Law360 article analyzing the Massachusetts Appellate Tax Board’s decision rejecting the state’s application of combined reporting rules to shielded entities under the Interstate Income Act (P.L. 86-272).
Gandhi noted that the decision differs from precedent in other states, such as Michigan, emphasizing, “It’s not quite the same question that the [board] was looking at.”
She added, however, that the rulings share a common theme, explaining that states “can’t try to cherry-pick within the unitary group” to limit tax credits or deny P.L. 86-272 protections.
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