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Represented Union Bank of California (UBOC) in a matter against the FTB involving the methodology which UBOC could use to compute its bad debt reserve deductions and deductions for securities losses for franchise (income) tax purposes in California. On behalf of UBOC, he asserted that the methodology originally applied by the FTB did not afford proper treatment to the losses suffered by the parent corporation of the group of corporations included in UBOC's California filing. The case involved technical issues regarding appropriate deductions under the California Revenue and Taxation Code, as well as constitutional issues. The case was settled with the FTB's agreement to refund tax and interest to UBOC in an amount in excess of $113 million.
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Represented Microsoft Corporation in a California corporation income tax dispute over the formula used to apportion Microsoft's income to the state for the purpose of determining how much of Microsoft's worldwide income can be taxed by California.
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Represented numerous corporations before state administrative agencies involving assessments of sales and use, income and franchise taxes
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Provided state sales tax planning advice for a multinational entity engaged in online retail/e-commerce and cloud computing
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Represented Union Bank of California (UBOC) in a matter against the California Franchise Tax Board (FTB) involving the methodology that UBOC could use to compute its bad debt reserve deductions and deductions for securities losses for franchise (income) tax purposes in California. The case involved technical issues regarding appropriate deductions under the California Revenue and Taxation Code, as well as constitutional issues. The case was settled with the FTB's agreement to refund tax and interest to UBOC in an amount in excess of $113 million.
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Advised a leading high tech equipment manufacturer concerning the income and sales tax implications of a series of complex domestic and international restructuring transactions.
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Samland Investment Company Limited v Inland Revenue Department, 2002 (acting for taxpayer seeking a review of the decision of the Commissioner of Inland Revenue in relation to tax assessed on a luxury residential property redevelopment project)
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Challenge to California employment insurance audit adjustments
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Constitutional challenge to the Illinois discriminatory alcoholic beverage tax provisions
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Successfully represented Federal Express in apportionment litigation in which the court agreed that the apportionment statue had to be interpreted in a manner that recognizes that only in-state activity should increase a taxpayers apportionment proportion. FedEx Ground Package System, Inc. v. Commonwealth, 303 F.R. 2003 (April 27, 2007).
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