Judge Compares Nordstrom’s IP Holding Company State Tax Play to Maligned Basketball Strategy

Judge Compares Nordstrom’s IP Holding Company State Tax Play to Maligned Basketball Strategy

ByJustin Hughes - JD, CPA, LLM

On Monday August 18, 2014, the Maryland Court of Appeals released its decision in NIHC v. Comptroller of the Treasury.[1] The counsel for Nordstrom must have known that things were not going to go their way when the opinion’s opening paragraph analogized their client’s “intellectual property holding company” (”IPHC”) tax planning to the historically successful,…

Recent Case: IBM v. Michigan Department of Treasury (Michigan Supreme Court)

ByJustin Hughes - JD, CPA, LLM

On Monday July 14th, the Michigan Supreme Court held in a split decision that IBM had the right to elect to use the evenly weighted three-factor formula from the Multistate Tax Compact (“MTC”) to apportion its income in calculating its 2008 Michigan taxes. The Michigan Department of Treasury argued that the Michigan legislature’s enactment of…