Contact: Thomas Steele or Paul Frankel
Morrison & Foerster is nationally recognized for its practice in the area of state and local taxation. The firm's tax attorneys
have represented clients in proceedings in virtually every U.S. state and currently have matters pending in more than half
of the states. This breadth of experience allows Morrison & Foerster to approach state and local tax problems from a nationwide
perspective, taking into account the similarities and differences of state and local tax systems throughout the U.S. The firm's
tax lawyers have been involved in many of the most important cases affecting state and local taxation, including a number
that have been heard by the U.S. Supreme Court.
The firm’s state and local tax clients have included Bristol Myers-Squibb, Citicorp, Control Data, General Motors, Hallmark,
Sherwin-Williams, Sony, Sumitomo, Wells Fargo, and W.R. Grace & Co.
Morrison & Foerster’s state and local tax work includes planning and consulting with clients regarding issues such as corporate
franchise and income taxes, sales and use taxes, real and personal property taxes, local business license taxes, gross receipts
taxes, telecommunications taxes, severance taxes, capital stock taxes, documentary and other transfer taxes, and personal
income taxes. In addition, the firm regularly advises clients on the state and local tax implications of a wide range of transactions
and corporate reorganizations, including multistate analyses of potential mergers, acquisitions and dispositions.
The firm also represents clients in administrative controversies and tax-related litigation. The firm has developed a specialized
expertise in the particular challenges of presenting state tax issues to courts of general jurisdiction, which often need
significant background education to deal with sophisticated tax issues.
Representative Matters
Successfully represented Hallmark in a corporate income tax controversy before the New York State Tax Appeals Tribunal, which
held that New York State could not force Hallmark Marketing to be combined with its out-of-state parent corporation for New
York State tax purposes.
Successfully represented The Kroger Co. in a corporate income tax controversy before the Colorado District Court, which held
that The Kroger Co. and certain combined affiliates could not be forcibly combined with other subsidiaries that had no nexus
with Colorado.
Successfully represented Toys "R" Us in a corporate tax controversy before the New York City Tax Appeals Tribunal, which held
that the City of New York could not force Toys "R" Us to be combined with its affiliated intangibles holding companies for
tax purposes.
