Michael A. Jacobs Photo

Michael's practice runs the gamut from state corporate income tax assessment appeals and refund claims to state tax planning in connection with business and real estate transactions. Michael has represented clients in the administrative and judicial appeals of state income tax issues in dozens of states, with particular experience in Pennsylvania, Massachusetts, Maryland and Virginia. Many of these appeals have resulted in multi-million dollar refunds or assessment reductions. Michael also advises public and private clients with respect to state and local income, sales and realty transfer tax issues in connection with reorganizations, acquisitions and divestitures throughout the U.S., as well as sales tax issues relating to acquisitions and divestitures of moveable property (aircraft, rail cars and barges). Michael also regularly counsels clients on their financial accounting provisions for state taxes.


  • Harvard Law School, 1992, J.D., cum laude
  • Yale University, 1989, B.A., magna cum laude

  • Virginie
  • District of Columbia
  • Massachusetts
  • Pennsylvanie

  • President, Philadelphia Bar Association State and Local Tax Committee, 2010-2011
  • Secretary, Philadelphia Bar Association State and Local Tax Committee, 2008-2009
  • Member of Philadelphia Bar Association Tax Council, 2011-2021
  • Tax Section of the American Bar Association
  • Former chair, Boston Bar Association Federal Tax and Business Transactions Committee

Notable Quotes

  • 12 January 2022 “Massachusetts Tax Board: Online Software Provider Can Use single Sales Factor,” Tax Notes
  • 6 February 2020 “Citrix Owes Massachusetts Sales Tax on Software Hosted Remotely” Tax Notes
  • 15 May 2019 “Massachusetts Judge Dismisses Suit Over Pre-Wayfair Online Sales Tax Reg” Tax Notes 
  • 2 May 2019 “Pennsylvania Details Tax Treatment of Section 163(j) Limitations” Tax Notes 
  • 12 November 2018 “Software From Remote Servers Is Taxable, Massachusetts Board Says” Tax Notes
  • 26 March 2018 "Virginia High Court Again Rules for State in Addback Statute Case" Tax Notes 
  • 17 January 2018 "Sales Tax Collections Hanging on Mass. Rule, SCOTUS Ruling" The Boston Globe 
  • 1 November 2017 "Massachusetts Company Must Directly Own Subsidiary for Deduction" Bloomberg BNA
  • 24 October 2017 "Massachusetts Mulling Modified Corporate Tax Nexus Regulation" Bloomberg BNA
  • 2 August 2017 "Wholesaler Liable for Tax in Massachusetts Drop Shipment Case" Tax Notes
  • 31 July 2017 "Massachusetts DOR Proposes Remote Sales Tax Collection Reg" Tax Notes
  • 27 June 2017 "Massachusetts DOR Updates Tax Return Guidance for Non-U.S. Corporations" Tax Notes
  • 10 April 2017 "Scope of Mass. Sales Tax Rule May Go Beyond Online Sales" Law360
  • 8 November 2016 "Massachusetts DOR Releases Updated Field Audit Manual" Tax Analysts
  • 5 November 2016 "Disproportionate Tax on Telecom Property Is Constitutional, Massachusetts High Court Holds" Tax Analysts
  • 3 November 2016 "Virginia Supreme Court Will Hear Case on Addback Exemption" Tax Analysts
  • 25 August 2016 "Maryland Tax Court Strikes Down State's Treatment of Federal Bond Interest" Tax Notes
  • 18 August 2016 “Refunds Possible After Massachusetts Loan Securitizer Case" Bloomberg BNA
  • 16 August 2016 “Bad News For Loan Co. Spells Refund Opportunity for Others” Law360
  • 15 August 2016 “Securitized Loan Interests Properly Assigned to Massachusetts, High Court Holds” Tax Analysts
  • 7 April 2016 "Massachusetts Tax Board Upholds Sales Tax on Distributor's Drop Shipments" Tax Analysts
  • 4 March 2016 "Pennsylvania Add-back Guidance Exceeds Statue, Critics Say; More Regulation Coming" Bloomberg BNA
  • 15 February 2016 "Virginia Says Addback Exception Applies Only to Royalties Taxed in Other States" Tax Analysts
  • 4 February 2016 "Pennsylvania DOR Releases Draft Guidance on Addback Provision," Tax Analysts
  • 3 November 2014 "Massachusetts Market Sourcing Regulations" Tax Analysts
  • 21 April 2014 "News Analysis: Does Virginia's Addback 'Clarification' Violate Due Process?" Tax Analysts
  • 7 April 2014 "Virginia Slips 10-Year Retroactive Addback Exception Limit into Budget Bill" Tax Analysts