MARCH 2002 A FOLEY & LARDNER TAX, VALUATION AND FIDUCIARY LITIGATION PUBLICATION IP HOLDING COMPANIES UNDER ATTACK MORE NEWS A Report from a Key State Income Tax Battleground Continuing Update on Tax Shelters The States have launched a full scale attack against intellectual property holding companies (“IP Holding Companies”). Dozens Following up on our February issue focusing on developments in of cases are in litigation across the country, and widely varying the Tax Shelter area, there are results have been reported from State to State. In this month’s more developments this month. newsletter, we will review recent developments and offer some thoughts on where IP Holding Company litigation is headed First, the IRS has announced that and what tax managers should do to strengthen the defenses its Penalty Waiver Program has of their IP Holding Companies. been a great success with almost 80 taxpayers making submissions One of the States’ key lines of attack is to assert expansive to the IRS by early March. Larry theories of nexus against IP Holding Companies whose only Langdon, Commissioner of the presence in the taxing State is the use of their intangible IRS’s Large and Mid-Sized assets. The States have scored significant nexus victories in Business Division was quoted as cases such as Geoffrey in South Carolina and Kmart Properties stating about the program: “We’re in New Mexico, but have also suffered defeats, notably in the learning about abusive shelter SYL, Crown Cork & Seal and MCI International techniques that even people from [the private sector] didn’t know Telecommunications cases in Maryland. about. We’re learning about The States have also attacked the deductions for royalties paid promoters we didn’t know about.” to an IP Holding Company by its affiliated group of operating As a condition to participation in companies (“Operating Group”). The States’ legal ammunition the program, taxpayers are required to provide the IRS with for this offensive includes: full documentation of the shelter • attacks upon the separate existence of IP Holding and the name of the promoter. As Companies under “business purpose,” “economic a result, the IRS is likely to demand that the promoters substance” or “sham transaction” doctrines, which disclose the name of all other traditionally have been associated with the federal income taxpayers who used the shelter tax technique. • denial or adjustment of deductions for royalties paid to IP In addition, the IRS has Holding Companies under State law authority similar to announced the formation of federal Section 482 of the Internal Revenue Code transaction specific task forces • assertion of statutory forced combination of distinct involving revenue agents, corporate entities attorneys from the Chief • imposing alternative apportionment formulae where the Counsel’s office, the Treasury statutory scheme does not “fairly represent” income earned Department and the Office of Tax Shelter Analysis. within the State. continued on next page PAGE 2 MARCH 2002 IP Holding Companies which have significant business activity, Continuing Update on Tax apart from licensing intellectual property back to the Operating Shelters, continued Group, should survive State attacks based upon economic substance, business purpose or sham transaction arguments. Part of the function of the task forces will be early identification In particular, patent management and trademark licensing of new abusive shelters and early companies with significant licensing to third parties outside their public notice challenging the affiliated Operating Group should not be susceptible to these shelters. attacks. Nevertheless, we expect that some States will continue to attack even the most substantial IP Holding On the legislative front, on March Companies utilizing expansive nexus theories, alternative 21, the Senate Finance apportionment formulae or outright denial of deductions on a Committee held hearings on variety of grounds. corporate tax shelters and several senators indicated that On the other hand, many IP Holding Companies formed in the they would be introducing new 1990s acquired trademarks or similar intangibles solely for the legislation to address abusive purpose of licensing back to the Operating Group, without shelters in the near future. In hiring any employees, acquiring any significant tangible connection with the hearings, the property or engaging in other business activity. These “paper Joint Committee on Taxation companies” are most susceptible to attack by the States on all released a detailed report on the current shelter situation. of the theories listed above, and tax managers should consider ways to add significant business activity to these paper companies to withstand attack by State auditors. What is an IP Holding Company? Illinois Proposes Rules for The structure of the typical IP Holding Company is fairly simple. Financial Organization The Operating Group creates the IP Holding Company as a Apportionment, 2 nd Tier corporate subsidiary in a State where there is no corporate Partnerships income tax (e.g., Delaware, for holding companies, or Nevada), The Illinois Department of or a State where receipt of royalty payments will not result in Revenue issued two important additional State tax (often the State of corporate domicile of the sets of proposed income tax Operating Group). The Operating Group transfers intellectual regulations in March. The first property or other intangible assets, including patents, proposed regulation provides trademarks, trade names, service marks and copyrights, to the guidance for the apportionment of IP Holding Company. The IP Holding Company then enters business income of financial into a license agreement, under which the Operating Group organizations, which in general agrees to pay the IP Holding Company a royalty in exchange include banks, investment for the exclusive or nonexclusive right to use the intellectual companies, sales finance property or intangible assets. companies and similar entities. The proposed regulation would This structure is designed to create deductions for royalties codify the position that dividends paid to the IP Holding Company, reducing the Operating and interest will be “received” Group’s income or franchise tax liability in States where it outside of Illinois if received in a operates. The IP Holding Company receives the royalties in a continued on next page PAGE 3 March 2002 tax-free or tax-neutral jurisdiction. The IP Holding Company Illinois Proposes Rules for typically can distribute tax-free dividends to its parent in the Financial Organization amount of the royalties paid, or loan its accumulated cash to Apportionment, 2 nd Tier the Operating Group. Partnerships, continued The IP Holding Company may license the intellectual property lockbox located outside Illinois or to independent third parties, and, indeed, some patents and by wire transfer to an account other intangible assets may generate revenues exclusively located outside Illinois. This from third party licensing. IP Holding Companies may proposed regulation will facilitate undertake the task of preventing infringement of the intellectual tax planning through the formation property, and, in some cases, may be used as a financing of sales finance company vehicle or carry out other business activities apart from subsidiaries, which can be licensing the intellectual property back to the Operating Group. separated from an otherwise unitary business group. Prop. IP Holding Companies are most effective to reduce income Reg. 100.3400. taxes in States which tax corporations on a separate basis. In The second proposed regulation States which require combined or consolidated reporting by the would amend the Illinois rule which Operating Group and the IP Holding Company, the deduction requires corporate partners to for royalty payments typically disappears as an intercompany include their proportionate share of elimination. In those “combined States,” an additional income and apportionment factors challenge is to structure the IP Holding Company to be of first-tier partnerships, but not separate from the unitary business group or consolidated lower-tier partnerships, in their group. combined income and factors. The proposed regulation would Direct Attacks on IP Holding Companies: State Attempts require a flow-up of income and to Assert “Nexus” Without Physical Presence factors of second-tier partnerships, Some States attack the IP Holding Company structure by but apparently not lower-tier seeking to tax the IP Holding Company directly, and for these partnerships. Prop. Reg. States, the threshold issue is “nexus” or jurisdiction to tax. For 100.3380(d). nexus to exist, the taxpayer’s connection to the taxing State Numerous two-tier partnership must satisfy both (1) a relatively low “minimum contacts” structures have been set up in threshold required by the Due Process Clause, which requires recent years to effectively only that the taxpayer purposefully directs its activities toward separate businesses from a the State’s economic forum, with or without physical presence unitary business group for Illinois there, and (2) a more exacting “substantial nexus” test required combined reporting purposes. by the Commerce Clause, which is the source of current The proposed regulations appear litigation controversy over whether some physical presence in to prevent this technique, although third-tier partnerships might still be the taxing State is required. separated from the unitary It has been clear since Geoffrey, Inc. v. South Carolina, 437 business group. The intended S.E.2d 13 (S.C. 1993), cert. denied, 510 U.S. 992 (1993), that effective date of the regulation is captive trademark companies established by retailers may be not yet clear. susceptible to nexus challenges by the States where the continued on next page PAGE 4 March 2002 affiliated retailer uses the trademark on a widespread basis, Illinois Proposes Rules for even though the IP Holding Company itself has no physical Financial Organization presence in the taxing State. However, the Geoffrey decision is controversial, and State courts remain divided on whether Apportionment, 2 nd Tier some physical presence is required by the “substantial nexus” Partnerships, continued requirement of the Commerce Clause, as interpreted in Quill The existing Illinois partnership Corp. v. North Dakota, 504 U.S. 298 (1992). regulation is the subject of litigation pending in the Illinois States in which nexus is the key inquiry – generally States Appellate Court, in which Foley & which apportion royalty income by place of use of the intangible Lardner represents the taxpayers. – have refined their nexus arguments and currently advocate BP Oil Pipeline Co. v. Department both direct and “representative” nexus theories in litigation. of Revenue, No. 01-2364, and The development of State nexus attacks on trademark Unocal Pipeline Co. v. Department companies over the past decade is illustrated by comparing of Revenue, No. 01-2365. Geoffrey with the recently decided case of Kmart Properties, Inc. v. Taxation and Revenue Department, Dkt. No. 21,140 (N.M. Ct. App., Nov. 28, 2001), appeal granted (Jan. 9, 2002). The Geoffrey Case. In Geoffrey, the taxpayer was a second- UPCOMING EVENT tier subsidiary of Toys R Us which owned trademarks and trade names which it licensed to the Toys R Us Operating Group. 2002 National Directors Institute The taxpayer did not have any physical presence in South May 9, 2002 • Chicago, IL Carolina, but also appeared to engage in little if any business The fall-out from the Enron activity, after its original license, in its domicile of Delaware. collapse continues to prompt The South Carolina Supreme Court first held that the IP increasing SEC and public scrutiny Holding Company had sufficient “minimum contacts” with South of the roles, duties and actions of Carolina to satisfy the low Due Process Clause threshold, boards of directors and audit without any physical presence in the State, because it committees. These circumstances “purposefully directed its activities toward South Carolina’s have caused directors to become economic forum... by licensing intangibles for use in South increasingly concerned about their Carolina and receiving income in exchange for their use.” responsibilities and potential liability. The South Carolina Supreme Court then concluded that the U.S. Supreme Court’s Commerce Clause analysis of To help directors, officers, corporate counsel and other “substantial nexus” in Quill does not require physical presence boardroom advisors better in the taxing State, except in the case of sales and use taxes at understand and address these issue in Quill. Although the Court recognized the “substantial difficult issues, Foley & Lardner is nexus” prong of Commerce Clause analysis, citing Complete sponsoring a National Directors Auto Transit, Inc. v. Brady, 430 U.S. 274 (1977), the Court Institute. nevertheless concluded that “substantial nexus” could be satisfied merely by “licensing intangibles for use in this State and deriving income from their use here.” continued on next page PAGE 5 March 2002 In effect, the South Carolina Supreme Court – without explicitly 2002 National Directors Institute, stating as much – extended the lower Due Process threshold of continued “purposeful direction of activity” toward the taxing State to its Commerce Clause analysis, and decided that the IP Holding The Institute will include Company met that lower threshold for nexus by the exclusive presentations and interactive licensing of the Toys R Us trademarks, trade names and panel discussions, featuring Arthur service marks to the Toys R Us Operating Group in South Levitt, Former Chairman of the Carolina. The Geoffrey Court also rejected the taxpayer’s Securities and Exchange contention, based on the outdated doctrine of mobilia Commission; Sarah Teslik, Counsel of Institutional Investors; sequuntur personam, that its intangibles must be sited solely to among others. its corporate domicile in Delaware. For more information, please send The Kmart Properties Case. Like the Geoffrey case decided an email—including your contact eight years earlier, Kmart Properties involved a captive information—to trademark subsidiary and illustrates the refinements in the email@example.com States’ direct nexus attack on IP Holding Companies. Kmart established its trademark subsidiary, Kmart Properties, as a Michigan corporation, with separate offices leased in its own name near Kmart’s headquarters and a separate payroll of five employees, including two intellectual property attorneys and support staff. Accordingly, the IP Holding Company was more than a mere paper corporation and apparently engaged in some trademark protection activity, although it licensed the trademarks to Kmart exclusively, for a royalty of 1.1 percent of sales, and apparently had no unaffiliated third-party licensees. The New Mexico Court of Appeals adopted the Geoffrey Court’s Commerce Clause analysis, stating that the “overarching substantial nexus test announced in Complete Auto Transit” does not require physical presence in the taxing State, and limited Quill’s precedential reach to sales and use taxes. In the Court’s view, the “use of Kmart Properties’ marks within New Mexico’s economic forum for the purpose of generating substantial income” was enough to provide “substantial nexus.” But the New Mexico Court of Appeals went further, and focused on the legal concept that a trademark and its goodwill are inseparable property rights that, as a practical matter, are bound to the business that generates the goodwill. The Court concluded that the value of the Kmart trademarks was inextricably tied to the operations of the Kmart retail stores in the State, and that Kmart Properties had established a physical continued on next page PAGE 6 March 2002 presence in New Mexico through the activities of the Kmart stores and employees located there, relying in part on the “representational” nexus cases of Tyler Pipe Industries v. Washington, 483 U.S. 232 (1987), and Scripto v. Carson, 362 U.S. 207 (1960). The New Mexico Court in Kmart Properties also upheld the State’s imposition of an alternative apportionment formula in order to tax the IP Holding Company. New Mexico’s three factor formula based upon payroll, tangible personal property and sales in New Mexico would not have apportioned any of the trademark company’s income to New Mexico. The Court upheld the revenue department’s use of a single gross receipts factor based upon the source of the royalties (i.e., the sales which gave rise to the royalty payments) under the UDITPA provision which permits alternative apportionment where the statutory formula does not “fairly represent” the income earned in the State. The Michigan- based payroll and property factors were excluded as de minimis, as they purportedly “played little or no role in how Kmart Properties generated its income.” The New Mexico Supreme Court has granted Kmart Properties’ appeal and may rein in the lower Court’s expansive reading of nexus, or it may recognize that the IP Holding Company’s legitimate business activity in Michigan should not have been excluded from the apportionment formula. The New Mexico Court of Appeals decision, if allowed to stand, provides a detailed roadmap to the States to argue that virtually all trademark licensing companies have nexus with the States in which the trademarks are used. Nexus Decisions in Maryland and Tennessee. To be sure, not all State courts agree with the conclusion in Geoffrey and Kmart Properties that there is no requirement of physical presence in the substantial nexus prong of the Commerce Clause, outside of the context of sales and use taxes considered in Quill. In a trio of decisions, the Maryland Tax Court declined to rule directly on whether the Commerce Clause requires “physical presence,” but then concluded that, absent physical presence, nexus did not exist to tax a trademark holding subsidiary, a trademark and patent holding subsidiary and a subsidiary which conducted MCI’s international calling functions through service agreements with its Operating Group. SYL, Inc. v. Comptroller, No. 24-C-99-002388 (Md. Cir. Ct., Mar. 17, 2000); Crown Cork & Seal (Delaware) Inc. v. Comptroller, No. 24-C-99-002389 (Md. Cir. Ct., Mar. 17, 2000); MCI Int’l Telecom. Corp. v. Comptroller, No. 24-C-99-002387 (Md. Cir. Ct., Mar. 17, 2000). The Maryland Circuit Court affirmed the Maryland Tax Court’s finding that these corporations were not “phantom entities” with no substance, and accordingly that nexus could not be attributed to them by reason of their relationship to their Operating Groups. The Tennessee Courts also have rejected the Geoffrey rationale in cases involving banking and internet “presence” within the State. In JC Penney National Bank v. Johnson, 19 S.W.3d 831 (Tenn. Ct. App. 1999), the Tennessee Appellate Court concluded that some physical presence is necessary to establish nexus and declined to find nexus where the bank’s only property within the State was thousands of credit cards held by its customers. In America Online Inc. v. Johnson, No. 97-3786-III (Tenn. Ch. Ct., Mar. 13, 2001), a lower court followed this reasoning and declined to impose nexus upon America Online, despite its widespread distribution of software diskettes within the State. continued on next page PAGE 7 March 2002 Despite these taxpayer victories, States will continue to attack trademark companies using the expanded nexus theories embraced by Kmart Properties. Trademark holding companies with substantial third-party licensing activities are better positioned than purely captive trademark companies to defend against nexus attacks and to prove that their business activity is in their headquarters State and not in the market States. Other types of IP Holding Companies, e.g., patent management companies where nexus or use in market States will be more difficult for the States to identify and prove, have even better defenses against nexus attacks than the active trademark companies. Nevertheless, the States will likely attempt to extend their nexus victories to all types of IP Holding Companies until the boundaries of nexus are more clearly drawn by litigation or by federal legislation. Indirect Attacks on IP Holding Companies: Deny the Royalty Deduction or Tax the Operating Group Several States have attempted to attack the corporate structure of IP Holding Companies through a growing variety of arguments, all focused on denying an Operating Group’s deduction for royalties paid to its IP Holding Company. Leading the States’ charge are two decisions of the Massachusetts Appellate Tax Board which illustrate the use of business purpose, economic substance, form over substance and sham transaction attacks upon the IP Holding Company structure. Syms Corp. v. Commissioner of Revenue, F215484 and F228324 (Mass. App. Tax Bd., Sept. 14, 2000); The Sherwin-Williams Co. v. Commissioner of Revenue, F23560 (Mass. App. Tax Bd., July 19, 2000). In Syms Corp., a well-known clothing retailer transferred trademarks to a Delaware subsidiary, SYL, Inc. (“SYL”), based upon the advice of outside professionals who presented Syms with a prepackaged plan to reduce State income taxes. Syms paid SYL a royalty of four percent of sales for the use of the trademarks. SYL conducted no other business, although it purportedly had one part-time employee who administered several hundred similar special purpose corporations and was paid an annual salary of $1,200. Royalty payments of over $10 million per year paid to SYL were almost immediately distributed back to Syms as a dividend, and Syms continued to undertake and fund all of the trademark protection functions after the transfer to SYL. Syms did not help its case by claiming royalty deductions on its Massachusetts tax returns for periods beginning three months before SYL was formed in Delaware and almost one year prior to the recordation of the assignment of the trademarks at the U.S. Patent and Trademark Office. The Massachusetts Appellate Tax Board, following federal case law, disallowed the royalty deductions on grounds that the transfer and license-back of the trademarks and the associated royalty payments should be disregarded as sham transactions which had no business purposes and no economic substance apart from tax avoidance. Syms attempted to counter this attack by contending that it had numerous business purposes for establishing the trademark subsidiary, including: better legal protection of the marks; isolation of the marks from potential hostile takeover bids; better management of the marks; protection of the Syms’ employees from legal dispute over the marks; enhanced ability to borrow funds; facilitation of corporate acquisitions, benefits of Delaware corporate law and judicial system; simplification of corporate accounting; and enhanced ability to enter into third-party franchising and licensing agreements for the use of the marks. continued on next page PAGE 8 March 2002 The Appellate Tax Board, however, upheld the Commissioner’s findings that these purported business purposes were not supported by the evidence, that Syms retained control over the marks and that the transaction was a “contrived mechanism” that lacked economic substance and should be treated “as if no transaction ever occurred.” For good measure, the Board found that the deduction should be disallowed on alternative grounds that the royalties were not ordinary and necessary business expenses as defined in Section 162 of the Internal Revenue Code, and that the Commissioner could adjust the royalty payments since they were in excess of fair value under Section 39A of the State revenue code, which is similar to federal Section 482. The Sherwin-Williams decision is similar, although in that case the trademark company engaged in a limited amount of licensing to third parties (less than one percent of its revenues), which the Massachusetts Appellate Tax Board found to be inconsequential. Syms is a spectacular taxpayer defeat, but presented a spectacularly bad set of facts – a truly “paper” trademark subsidiary with no provable business activity apart from the paper licensing of its trademarks back to the parent. The Syms decision, when contrasted with the Maryland decision in Sherwin-Williams described above, illustrates how State law doctrines vary widely and litigation outcomes depend upon State-specific precedent. IP Holding Companies which have significant business activity, particularly significant licensing to third parties, should be able to survive State attacks based upon economic substance, business purpose or sham corporation arguments, perhaps even from States such as Massachusetts that apply these doctrines aggressively. Requirement to File Combined or Consolidated Returns New York Forced Combination. New York State and New York City have taken a different line of attack on IP Holding Companies by invoking statutory requirements for forced combination of affiliated corporations. Under New York law, where there are substantial inter-corporate transactions, a rebuttable presumption of distortion of income on separate franchise tax returns arises, and taxpayers are forced to file a combined return. However, taxpayers who rebut the presumption of distortion of income by showing that the inter-corporate transactions were at arm’s length are entitled to file separate returns, and the burden of proof of actual distortion shifts to the State. In a series of highly detailed factual cases before the New York State Division of Tax Appeals and the New York City Tax Appeals Tribunal, corporate taxpayers have been successful in rebutting the presumption of distortion of income and thereby preventing forced combination. In re Sherwin-Williams Co., DTA No. 816712 (NYS Div. Tax App., Jun. 7, 2001); In re Toys “R” Us-NYTEX Inc., TAT 93-1039(GC) (NYC Tax App. Trib., ALJ Div., Aug. 4, 1999; In re Express, Inc., DTA Nos. 812330-812332 (NYS Div. Tax App., Sep. 14, 1995). The key to these taxpayer victories was the taxpayers’ ability to prove that the licensing agreements were at arm’s length and did not distort the income of the Operating Group. However, in one case the taxpayer was unable to prove that the transactions were at arms’ length and succumbed to forced combination. In re Burnham Corp., DTA No. 814531 (NYS Div. Tax App., July 10, 1997). continued on next page PAGE 9 March 2002 Note that the Sherwin-Williams case in New York was decided on facts essentially the same as the Massachusetts Sherwin-Williams case, again illustrating the wide variance of State statutory law and judicial doctrines which confront both taxpayers and the States when defending or attacking IP Holding Companies. Illinois Combination for Unitary Business Groups. Illinois requires combined reporting by unitary business groups as a general rule, whether or not distortion of income is present. As a result, IP Holding Companies ordinarily can reduce Illinois income taxes for the Operating Group only if the IP Holding Company can be separated from the rest of the unitary business group. In Zebra Technologies Corp. v. Topinka, No. 98 L 50479 (Cir. Ct. Cook County, July 23, 2001), appeal pending, the taxpayer transferred patent rights to a Delaware subsidiary corporation which maintained an office, a part-time employee with no apparent expertise in patent administration, and a personal computer in Hamilton, Bermuda. The Bermuda office was established to satisfy the Illinois “80/20 rule,” which excludes a corporation from the Illinois combined group if eighty percent of its payroll and property is located outside the United States. The Illinois Circuit Court concluded that most of the activity of protecting the value of the patent and trademark rights was performed by the parent company’s employees in Illinois and, without significant analysis of the payroll and property factors and whether the 80/20 rule was technically satisfied, rejected the taxpayer’s position by stating that “Zebra did not meet its burden of proof by showing that 80% or more of its business activities took place outside of the United States.” Although the Court did not expressly invoke the business purpose doctrine, which has not yet been adopted by the Illinois Appellate Courts, in another portion of its opinion, the Court found that a foreign sales corporation chartered in the Virgin Islands did not meet the 80/20 test and “served no valid business purpose, only tax avoidance.” The Zebra Technologies case is on appeal, and the ultimate decision will reveal whether or not the Illinois Appellate Courts will embrace business purpose or substance over form doctrines. Whatever the outcome, taxpayers should consider alternative methods of separating an IP Holding Company from the Illinois combined group, such as combining the IP Holding Company functions with a “financial organization” as defined in Illinois law. Concluding Thoughts Despite the fact that many States have attacked IP Holding Companies as abusive tax shelters, IP Holding Companies with real business purposes and activity should withstand most of the States’ legal challenges. On the other hand, it is doubtful that pre-packaged “paper” IP Holding Companies can withstand attack in many States, and litigation of these difficult cases could create precedent that is detrimental to IP Holding Companies with real business activity. Companies that have established IP Holding Companies should review their operations to determine whether there is sufficient business substance to protect against attacks on business purpose, economic substance, or sham transaction grounds. To withstand attack, IP Holding Companies should continued on next page PAGE 10 March 2002 have property, business activity, employees with substantial For More Information business functions and, if possible, significant licensing to unrelated parties. IP Holding Companies without significant To learn more about our Federal and business activity, apart from licensing intellectual property back State Tax Controversy services, please to the Operating Group, should consider moving trademark or call your Foley & Lardner attorney or patent maintenance and protection functions or other business feel free to contact one of the individuals activities into the IP Holding Company. In addition, inter- listed below. company licensing agreements should be reviewed periodically Fred Ackerson and royalty rates should be compared to market rates and firstname.lastname@example.org substantiated by appraisal. 312-755-2692 The battle over IP Holding Companies will continue to be John Palmer fought State by State. Taxpayers can win the battle by email@example.com understanding the emerging legal doctrines and adjusting the 312-558-6787 business activity and substance of their IP Holding Companies to satisfy the requirements of the States in which they operate. Maureen McGinnity firstname.lastname@example.org 414-297-5510 Mike Woolever email@example.com 312-558-6647 www.FOLEYLARDNER.com Associated Services Valuation Litigation Steve Lambert firstname.lastname@example.org Insurance Tax Controversy Richard Bromley email@example.com Estate and Trust Litigation John Brooks Legal News: Federal and State Tax Controversy firstname.lastname@example.org This publication is one of several newsletters published by Foley & Lardner’s Tax, Valuation & Fiduciary Litigation [TVFL] team. TVFL provides a unique blend of skilled litigators and tax attorneys to successfully represent clients in risk management, dispute resolution and litigation services. Specialties include Federal Tax Controversy, State Tax Controversy, Valuation Litigation, Insurance Tax Controversy and Estate and Trust Litigation.
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