State & Local Tax

It is an enormous challenge for businesses and individuals to understand and ensure compliance with the thousands of varied tax regimes that states and localities impose. Sullivan & Worcester has unusual depth of resources to help you meet the challenge. Moreover, we have long been recognized as a leader in the resolution of state and local tax disputes from the audit to the appellate court level. We are also experienced in sale/use tax cases involving private airplane purchases and leases. Our state and local tax group includes attorneys with many years of experience at high levels in tax agencies as well as in private tax practice. We work collaboratively to bring you advice that is informed by much more than book knowledge alone.

Practice Profile (PDF)

Representative Client Work

• Represented Fortune 500 companies, closely held businesses and individuals in some of the largest and most important tax controversies in Massachusetts
• Assisted a national retailer in resolving a sales- and use-tax dispute involving cross‑border sales
• Represented television stations in sales-tax disputes regarding the acquisition of broadcasting rights
• Advised high-net-worth individuals in connection with domicile planning and disputes
• Helped a large environmental services company integrate operations after a major acquisition so that state taxes would be dramatically reduced
• Assisted large multistate businesses and high-net-worth individuals in the voluntary disclosure of their non‑filing
• Analyzed state and local tax exposures for purposes of establishing financial statement reserves
• Assisted companies in qualifying for special, favorable tax regimes and discretionary credits and incentives
• Reviewed all significant intercompany pricing arrangements of a complex multistate financial services business for compliance with arms-length pricing principles
• Defended officers and employees who have been assessed tax as "responsible persons"
• Represented a Massachusetts corporate trust in a dispute involving the application of the Massachusetts "sting tax" to the sale of its qualified subchapter S subsidiary
• Advised a Louisiana municipality regarding the funding mechanism for its energy efficiency programs

Recent Developments

For a discussion of recent developments in the Massachusetts tax laws, please see the following:

Massachusetts Finalizes Combined Reporting Regulations
State Tax Notes, July 13, 2009
Joseph X. Donovan, David J. Nagle and Sarah D. Wellings wrote an article entitled "Massachusetts Finalizes Combined Reporting Regulations," which discusses the Massachusetts Department of Revenue's regulation on the state's new combined reporting regime, which was enacted in July 2008 and took effect for tax years beginning on or after January 1, 2009.

Redline illustrating the differences between the final version of 830 CMR63.32B.2, promulgated on May 29, 2009, and the working draft version, released on November 6, 2008 (for discussion purposes only).

New Regs Set the Framework for Combined Reporting in Massachusetts
State Tax Notes, February 9, 2009
Joseph X. Donovan, David J. Nagle and Sarah D. Wellings wrote an article entitled "New Regs Set the Framework for Combined Reporting in Massachusetts," which discusses the Massachusetts Department of Revenue's regulation on the state's new combined reporting regime, which was enacted in July 2008 and took effect for tax years beginning on or after January 1, 2009.

Radical Tax Changes on the Horizon for Massachusetts
State Tax Notes, September 15, 2008
Joseph X. Donovan and Sarah D. Wellings wrote an article entitled "Radical Tax Changes on the Horizon for Massachusetts," which discusses the most far-reaching corporate tax changes to have been enacted in Massachusetts in the last 30 years.

Massachusetts Combined Reporting Proposal Survives Study And Becomes Law
State Tax Notes, July 21, 2008
Joseph X. Donovan and Sarah D. Wellings co-authored "Massachusetts Combined Reporting Proposal Survives Study And Becomes Law," which appeared in the July 21st issue of State Tax Notes.