State and Local Income Tax Litigation Cases Not to Miss TEI Dallas SALT Day Program

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1 State and Local Income Tax Litigation Cases Not to Miss TEI Dallas SALT Day Program October 17, 2017 Carley A. Roberts Partner Liz S. Cha Associate 2017 (US) LLP All Rights Reserved. This communication is for general informational purposes only and is not intended to constitute legal advice or a recommended course of action in any given situation. This communication is not intended to be, and should not be, relied upon by the recipient in making decisions of a legal nature with respect to the issues discussed herein. The recipient is encouraged to consult independent counsel before making any decisions or taking any action concerning the matters in this communication. This communication does not create an attorney-client relationship between (US) LLP and the recipient. (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under. For a full description of the structure and a list of offices, please visit

2 Agenda Income Tax Nexus Apportionment Sourcing Developments Alternative Apportionment Business/Nonbusiness Income Deductions Combined Reporting Transfer Pricing Other Income Tax Controversy Updates U.S. Supreme Court Update

3 Income Tax Nexus

4 Iowa Nexus Creating Activities Myria Holdings Inc. v. Iowa Dep t of Revenue, 892 N.W.2d 343 (Iowa March 24, 2017) The Iowa Supreme Court found that a group s parent company could not be joined in the filing of a consolidated Iowa income tax return because it lacked nexus with Iowa. In addressing the creation of nexus, the court determined that: The parent company s management and administration activities performed on behalf of the subsidiaries doing business in Iowa do not create nexus; and Ownership of subsidiary stock and money from reimbursements fell within the ownership and control safe harbor. 4

5 Iowa Holding Company Lacks Nexus Romantix Holdings Inc. v. Iowa Dep t of Revenue, No (Iowa Ct. App. May 3, 2017) The Iowa Court of Appeals upheld the Department s determination excluding an out-of-state holding company from an Iowa consolidated return due to lack of nexus even though it held intangible property used in Iowa by its subsidiaries. Citing Myria Holdings Inc., the court reasoned that it was clear the Iowa subsidiaries and their intangible property were not enough to establish a taxable nexus with Iowa sufficient to remove the parent from the Iowa safe harbor provisions. 5

6 Apportionment Sourcing Developments

7 Oregon Sourcing Online Educational Services Apollo Educ. Grp. Inc. v. Or. Dep't of Revenue, TC-MD C (Or. Tax Ct. Aug. 24, 2017) The Oregon Tax Court upheld the Department s assignment of revenue from online educational services to the location of course instructors. The course instructor costs were the only incremental direct cost to be considered in determining the location of the costs of performance. 7

8 Texas Apportionment of Services Private Letter Ruling No L, Texas Comptroller of Public Accounts (Mar. 15, 2017) The Comptroller ruled that receipts from risk and fraud prevention services are sourced to the customer s location. Texas sources service receipts to the location where services are performed. The Comptroller interprets where services are performed based on the location of the end-product act, which, under the Comptroller s view, does not include non-receipt producing, albeit essential, support activities. The Comptroller found that the end-product act is the taxpayer s response to service requests, which are provided at customer locations. 8

9 New York Services Allocable to Activity Location In the Matter of Catalyst Repository Systems Inc., No (N.Y. Div. Tax. App. August 24, 2017) The Administrative Law Judge (ALJ) determined that online litigation support services receipts are services and allocated to the location where the services were performed, which were outside of New York. In the Matter of the Petitions of Checkfree Services Corp., Nos & , 2017 WL (N.Y. Div. Tax. App. January 5, 2017) The ALJ determined that a taxpayer s electronic bill payment and presentation receipts constitute service receipts and not other business receipts, and are properly sourced where the service is performed. 9

10 Alternative Apportionment

11 Invoking Alternative Apportionment Moving Party Assert Distortion? Yes Proposed Reasonable Alternative? Yes Alternative Apportionment No No No Alternative Apportionment No Alternative Apportionment Burden of proof is on the party seeking to diverge from the standard apportionment formula to prove that distortion exists, and that a proposed alternative method is reasonable. 11

12 Virginia Statutory COP Method Upheld Corporate Executive Board v. Va. Dep t of Taxation, No. CL (Va. Cir. Ct. Sept. 1, 2017) The Virginia Circuit Court held in favor of the Department of Taxation s use of the statutory COP method to apportion income from the sales of subscription-based services because use of the COP method did not lead to inequitable results and was not unconstitutional. The court found that under the COP method, most of the taxpayer s sales originated in Virginia and were attributable to the state. The court rejected the taxpayer s request for alternative apportionment using market-based sourcing and characterized the request as arbitrary. 12

13 Colorado Improper Use of Alternative Apportionment Target Brands, Inc. v. Dep t of Revenue, No. 2015CV33831 (Colo. 2nd Dist. Ct. Jan. 27, 2017) A Colorado district court found that despite lacking any physical presence in state, subsidiary that managed company s brands had substantial nexus in Colorado because its IP licenses were used there. However, Department of Revenue s use of its alternative apportionment authority to exclude subsidiary s substantial out-of-state property and payroll from apportionment factors was unreasonable. 13

14 Minnesota Alternative Apportionment Struck Down Associated Bank, N.A. v. Comm r Revenue, No R, 2017 WL (Minn. Tax Ct., Reg. Div. Apr. 18, 2017) The Minnesota Tax Court found that the Commissioner could not invoke alternative apportionment to include interest income and intangible property in the apportionment factor of LLCs subject to the general apportionment formula, which excludes these items from the factors. The taxpayer s lawful business structure could not be disregarded. The taxpayer created two LLCs to conduct business in Minnesota, which defines a financial institution as a corporation. The taxpayer excluded the LLCs interest income under the general apportionment rules and avoided the LLC interest income inclusion rules applicable to financial institutions. On appeal with the Minnesota Supreme Court. In a special legislative session, the Minnesota Legislature amended the definition of a financial institution to include both corporations and other business entities effective after December 31,

15 South Carolina Alternative Apportionment Also Struck Down! Rent-a-Center West v. DOR, 418 S.C. 320 (SC Ct. App. 2016) The South Carolina Court of Appeals determined that a taxpayer could utilize the state s standard threefactor apportionment formula, and rejected a challenge by the South Carolina Department of Revenue to require alternative apportionment based on the argument that the statutory method used by the taxpayer was distortive. The party seeking to use an alternative apportionment method bears the burden of proving by a preponderance of the evidence that (1) the statutory formula does not fairly represent the taxpayer's business activity in South Carolina and (2) its alternative accounting method is reasonable. 15

16 Business/Nonbusiness Income

17 California Moment of Judgment Is Decisive in Applying Functional Test Fidelity National Information Services, Inc. v. Franchise Tax Board (Cal. Ct. App., July 27, 2017, No. C081522) (unpublished) Issue: Whether $309 million of capital gains from the sale of a minority stockholding was business income subject to tax by California Court of Appeal held the functional test must be applied at the moment of judgment, i.e., when the decision to sell is made 17

18 South Carolina Narrow Transactional Approach DIRECTV Inc. v. S.C. Dep t of Revenue, No (S.C. Ct. App. Aug. 30, 2017) The court affirmed the administrative law court s (ALC) decision finding that DIRECTV s income-producing activity is solely the delivery of a signal to its customers nationwide. Accordingly, 100% of subscription receipts to South Carolina customers is attributed to South Carolina. The court found the proper burden of proof ( preponderance of evidence ) was applied to DIRECTV. The court affirmed the ALC s assessment of underpayment penalties because there was no reasonable cause for DIRECTV s underpayment. 18

19 Indiana Subsidiary Sale = Nonbusiness Income; Intercompany Loan Had Substance E.I. DuPont De Nemours & Co. v. Ind. Dep t of State Revenue, 79 N.E.3d 1016 (Ind. Tax. Ct. July 11, 2017) The Indiana Tax Court held that gain on a subsidiary sale was nonbusiness income because the taxpayer was not engaged in the business of selling subsidiaries and the taxpayer and its subsidiary were not centrally managed and did not benefit from economies of scale. The court also found that interest related to intercompany loans was deductible for interest payments that were accrued but not paid because the interest rates were arm s length and the Department failed to show a lack of economic substance. The court also found that the Department has the authority to make NOL adjustments in years that are closed to assessment under the statute of limitations. 19

20 New Jersey Gain From 338(h)(10) Is Nonbusiness Xylem Dewatering Solutions, Inc. v. Dir., Division of Taxation, 30 N.J.Tax 41 (N.J. Tax Ct. April 7, 2017) Gain from a deemed asset sale under I.R.C. 338(h)(10) recognized by a New Jersey-based S corporation was nonoperational (nonbusiness) income. Treated as nonbusiness income, the receipts are 100% allocable to New Jersey, rather than subject to apportionment. 20

21 Combined Reporting

22 Minnesota Inclusion of a Foreign Disregarded Entity Ashland, Inc. v. Comm r of Revenue, 899 N.W.2d 812 (Minn. Aug. 2, 2017) The Minnesota Supreme Court affirmed that an election made under federal tax law by a foreign entity owned by the taxpayer, a domestic unitary business, must be recognized in determining the taxpayer s Minnesota tax liability. Including in net income the income of a foreign entity that elects under federal tax law to be disregarded as a separate entity does not violate Minnesota s water s edge law because the disregarded entity does not retain a nationality separate from its owner under Minnesota tax law. 22

23 Michigan Meaning of Indirect Ownership LaBelle Management, Inc. v. Dep t of Treasury, 888 N.W.2d 260 (Mich. Ct. App. 2016), leave to appeal denied, 889 N.W.2d 250 (Mich. Jan. 24, 2017) The Michigan Court of Appeals held that three companies did not constitute a statutorily defined unitary business group for Michigan Business Tax (MBT) purposes because there was insufficient direct and indirect ownership. Under the MBT, a unitary group is defined, in part, as a group of US persons one of which owns or controls directly or indirectly more than 50% of the ownership interest of the other members. Department of Treasury adopted a constructive ownership requirement using IRC 318 attribution rules to determine indirect ownership. Court determined that the Department s adoption of a constructive ownership test in determining unitary group control was improper. On February 28, 2017, the Department of Treasury issued a notice addressing the impact of LaBelle and announced its retroactive application. 23

24 New York Substantial Intercorporate Transactions In the Matter of Whole Foods Market Group, Inc., No (N.Y. Tax App. Trib. Sept. 11, 2017) The Tax Appeals Tribunal held that Whole Foods and its related IP holding company must file a combined report based on substantial intercorporate transactions (the combination test under the pre-tax Reform law). The Tax Appeals Tribunal disagreed with the taxpayer s assertion that royalty payments that the taxpayer added back in computing entire net income must be excluded from the substantial intercorporate transaction analysis. 24

25 Deductions

26 Statutory Disallowance Background States using statutory disallowance to combat intercompany transactions Addback statutes disallow otherwise allowable deductions for expenses paid to affiliates Common exceptions to addback statutes Recipient subject to tax on income in excess of a benchmark rate Recipient is in a foreign country with US income tax treaty Specific industry exceptions Recipient is a conduit for payment to third parties Parties elect to file on a combined basis Unreasonable exception 26

27 Virginia Subject to Tax Addback Kohl s Dep t Stores, Inc. v. Virginia Dep t of Taxation, 803 S.E.2d 336 (Va. Aug. 31, 2017) The Virginia Supreme Court found that only the portion of royalties that are actually taxed by another state falls within its subject to tax exception to Virginia s addback statute for corporate income tax purposes. The Court acknowledged that the plain language of the statute is ambiguous and that both parties respective positions could be supported by the statute. The Court deferred to the Department s interpretation. The case has been remanded to the Circuit Court to determine the portion of the royalty payments actually taxed by another state. 27

28 New Jersey Satisfying the Unreasonable Exception BMC Software, Inc. v. Dir., Div. of Taxation, 30 N.J.Tax 92 (N.J. Tax Court May 24, 2017) The New Jersey Tax Court found that a subsidiary s intangible expenses paid to its parent qualified for the state s unreasonable addback exception because the payments were substantively equivalent to an unrelated party transaction. The court held that: The unreasonable exception does not require showing that the related-party recipient paid Corporation Business Tax on the income. Showing that the related-party transaction was substantively equivalent to an unrelated third-party transaction is sufficient evidence for the addback is unreasonable. 28

29 Alabama Tax Tribunal Denies Addback Exceptions Credit Suisse First Boston USA Inc. v. Ala. Dep t. of Revenue, No. BIT (Ala. Tax Tribunal, Sept. 7, 2017) The Tax Tribunal affirmed the Department s additional 2016 business income tax assessment related to the taxpayer s denied deductions for interest expenses paid to related members. The Tax Tribunal found: The taxpayer failed to meet the treaty exception because it failed to provide necessary documentation to show that the interest expenses paid to related companies were subject to a tax in a foreign jurisdiction that had an income tax treaty with the United States. The taxpayer did not meet its burden to show that the transactions giving rise to the interest expenses had a substantial business purpose, economic substance, and arm slength terms and conditions. 29

30 Texas Cost of Goods Sold Deduction American Multi-Cinema Inc. v. Hegar, No CV, 2017 WL (Tex. App. Austin Jan. 6, 2017), pet. filed, No (Tex. Aug. 16, 2017) The Texas Court of Appeals held that a movie theater chain was entitled to deduct costs of goods sold (COGS), even though the statute excluded taxpayers that sell intangibles or services. The court s original opinion determined that AMC qualified for the COGS deduction because its film exhibitions were perceptible to the senses, and therefore qualified as tangible personal property eligible for the COGS deduction. A year later, the court issued a substitute opinion (in response to the Comptroller s motion for rehearing) instead finding that AMC qualified under the second definition of tangible personal property, which expressly includes films, sound recordings, videotapes, [and] live and prerecorded television and radio programs. The court also rejected the Comptroller s argument that AMC does not sell tangible personal property because customers leave AMC s theaters with experiences and memories but without a copy of the film. The court concluded that the COGS statute does not contain a take-home requirement. The Comptroller filed a second motion for rehearing, which the court denied, and the Comptroller then filed a petition for review at the Texas Supreme Court. The Comptroller estimates that the Court of Appeals decision in AMC will have a fiscal impact of $1 billion annually. 30

31 North Carolina Market Discount Income Interest The Fid. Bank v. N.C. Dep t. of Revenue, 803 S.E.2d 142 (N.C. Aug. 18, 2017) The North Carolina Supreme Court upheld the determination that the taxpayer was not entitled to deduct the market discount income as interest on US obligations for North Carolina corporate income tax purposes. The court held that the fact that market discount income is treated as interest for purposes of determining federal taxable income does not mean that market discount income should be treated as interest for all purposes under the North Carolina Revenue Act. Indiana has selective IRC conformity. While interest is undefined under North Carolina law, the term was interpreted under the plain meaning involving periodic payments received by the holder of a bond. 31

32 Alabama Dividends From REIT Are Deductible Ameris Bank v. Ala. Dep t of Revenue, No. BIT , 2017 WL (Ala. Tax Trib. Feb. 9, 2017) The Alabama Tax Tribunal held that a taxpayer banking corporation properly deducted dividends received from an affiliated real estate investment trust (REIT) for financial institution excise tax purposes because the REIT qualified as a corporation. The Tribunal rejected the Department of Revenue s assertion that the REIT was not a corporation based on its tax treatment as a REIT, explaining that the deduction applies more broadly to dividends received from payor entities that are corporations organized and existing under Alabama law. The Tribunal held that the REIT did not meet the requirements to qualify as a bank. 32

33 Transfer Pricing

34 Overview of State Transfer Pricing Issues State Use of Transfer Pricing Authority Historically, few states have actively utilized 482 equivalent authority States rely on formulary apportionment for determining where corporate income is earned. By contrast, the United States and virtually every other nation rely on transfer pricing for sourcing cross-border income. States have limited experience with transfer pricing and few resources trained to apply transfer pricing rules as compared with the IRS or foreign taxing authorities. States have also utilized other solutions for policing related party transactions. E.g., asserting nexus, addback provisions, etc. Rather than engaging in a substantive pricing analysis, states are increasingly either: Disregarding intercompany transactions; or Disallowing 100% of tax outcome by arguing that the transactions are per se distortive. 34

35 Overview of State Transfer Pricing Issues Increased Interest in State Transfer Pricing Over the last few years, interest in transfer pricing has increased among the states. In part, this is due to the global attention accorded to the problem of cross-border income taxation and to the OECD Base Erosion and Profit Shifting (BEPS) Project. It is also attributable to the publicity surrounding the Multistate Tax Commission s (MTC) State Intercompany Transaction Advisory Service (SITAS) project. In particular, many states with separate entity reporting have expressed interest in expanding their transfer pricing audit capabilities. Non-arm s length intercompany transactions can impact the clear reflection of income in separate entity or partial combination reporting states. 35

36 Utah Reigning in Use of State Transfer Pricing Adjustments See s Candies, Inc. v. Auditing Div. of the Utah State Tax Comm n, No (Utah Dist. Ct. 2016) See s Candies deducted IP royalty payments made to an insurance company also owned by Berkshire-Hathaway. The Tax Commission argued that it could adjust See s income for the royalty payments based on the state s 482-style adjustment statute without reference to federal rules on related-company adjustments. The Utah District Court found that the Tax Commission abused its discretion by denying the entire intercompany royalty expenses when the Tax Commission failed to consider federal 482 guidance and failing to look at the taxpayer s transfer-pricing study. On appeal at the Utah Supreme Court. 36

37 District of Columbia Chainbridge Methodology Hess Corporation, et al. v. Office of Tax & Revenue, Nos OTR , 2011-OTR-00047, 2011-OTR (D.C. Office of Admin. Hearings March 15, 2017) In 2012, in Microsoft, the Office of Administrative Hearings (OAH) held that the Office of Tax and Revenue s (OTR) reliance on the transfer pricing methodology employed Chainbridge was arbitrary, capricious, and unreasonable and cannot form the basis for a determination to reallocate income between Microsoft and its affiliated businesses. The OAH found that the methodology improperly considered all of Microsoft s transactions, whether controlled or uncontrolled, in analyzing its profit-to-cost ratio and failed to compare specific types of Microsoft transactions to uncontrolled transactions. While Microsoft was pending, ExxonMobil Oil Corp., Hess Corp., and Shell Oil Co. were assessed additional corporate franchise tax by the OTR using the Chainbridge methodology. In 2014, the OAH granted summary judgment in favor of the taxpayers holding that the OTR was collaterally estopped from re-litigating the methodology. In 2016, the DC Court of Appeals held that the OAH abused its discretion and remanded the case to determine whether exceptional circumstances existed for collateral estoppel. On March 15, 2017, on remand, the OAH held that exceptional circumstances did not exist for collateral estoppel. Oral hearing on the merits of the case was held on September 14,

38 Other Controversy Updates

39 Wisconsin Can t Tax Licenses To Remote Manufacturers Microsoft Corp. v. Wis. Dep t of Revenue, No. 13-I-042 (Wis. Tax App. Comm n Aug. 10, 2017) The Wisconsin Tax Appeals Commission ruled in favor of Microsoft holding that the Department could not assess additional corporate franchise tax on Microsoft s royalty income earned from the licensing of its software to outof-state original equipment manufacturers that made sales to Wisconsin users. The licensing is an activity that takes place outside of Wisconsin and cannot be taxed regardless of where the ultimate customer is located. 39

40 Pennsylvania Net Loss Carryover Unconstitutional RB Alden Corp. v. Commw., 142 A.3d 169 (Pa. Commw. Ct. Sept. 12, 2017) The Pennsylvania Commonwealth Court held that the state s statutory cap on net operating loss (NOL) carryovers is unconstitutional. For the years at issue, taxpayers could carry over NOLs up to $2 million. The court held that this cap violates the state constitution s Uniformity Clause, because it creates two classes or groups of taxpayers: (1) those with income greater than $2 million, and (2) those with income equal to or lesser than $2 million. A taxpayer in the first group would owe tax even if it generated NOLs in excess of $2 million in earlier years. In contrast, a taxpayer in the second group could reduce its income to $0 and pay no tax. The court explained that the amount of a taxpayer s income is not a reasonable basis on which to treat taxpayers differently. The court rejected both parties exceptions to its decision on September 12th. 40

41 New York City Net Operating Losses Source Year In the Matter of Plasmanet, Inc., No. TAT(E)12-17(GC), 2017 WL (NYC Tax App. Trib. Jan 20, 2017) On January 20, 2017, the tribunal held that for general corporation tax (GRT) purposes, the taxpayer may only deduct NOLs from the same source year as its federal NOL deductions. The same source year rule applies. 41

42 California Fee vs. Tax vs. Something Else California Chamber of Commerce v. State Air Resources Board, 10 Cal. App. 5th 604 (2017)( Morning Star decision) Decided on April 6, 2017 Whether California s cap-and-trade auction is an unconstitutional tax because it was not enacted by a two-thirds majority as required by the California Constitution (as amended by Prop. 13). The court concluded the prior tax and fee test under Sinclair Paint was inapplicable because the voluntary auction fell outside the Sinclair Paint analysis and into a something else category 42

43 US Supreme Court Update

44 U.S. Supreme Court Docket Petition for Writ of Certiorari Fl. Dep t of Revenue v. DIRECTV, Inc., 215 So.3d 46 (Fl. Apr. 13, 2017) Denied Petitions Dot Foods Inc. v. Wash. Dep't of Revenue, 185 Wash.2d 239 (Wash. 2016) Gillette Comm. Ops. N. Am. v. Mich. Dep t of Revenue, 312 Mich.App. 394 (Mich. Ct. App. 2015), denying appeal, 499 Mich. 960 (Mich. 2016) First Marblehead Corp. v. Comm r of Revenue, 475 Mass. 159 (Mass. 2016) Fl. Dep t of Revenue v. American Business USA Corp., 191 So.3d 906 (Fl. 2016) Direct Marketing Ass'n v. Brohl, 814 F.3d 1129 (10th Cir. 2016) Matkovich v. CSX Transp., Inc., 793 S.E.2d 888 (W.Va. 2016) Irwin Naturals v. Wash. Dep t of Revenue, 195 Wash.App. 788 (Wash. 2016) T. Ryan Legg Irrevocable Trust v. Testa, 149 Ohio St.3d 376 (Ohio 2016) 44

45 Florida No Dormant Commerce Clause Violation Fl. Dep t of Revenue v. DIRECTV, Inc., 215 So.3d 46 (Fl. Apr. 13, 2017) In 2005, satellite companies brought action against the Department of Revenue, seeking an injunction, a refund, and a declaration that a provision of the Communications Services Tax Simplification Law imposing a 6.8% tax rate on cable service and a 10.8% tax rate on satellite service is unconstitutional for favoring cable companies. In 2013, the trial court disagreed with the satellite companies finding no violation of the Commerce Clause because the law does not benefit in-state economic interests or similarly situated entities. In 2015, on appeal, the First District reversed the trial court s decision finding that satellite companies and cable companies are similarly situated and that cable companies are an in-state interest due to the local infrastructure and employment. In 2017, the Florida Supreme Court held satellite and cable companies were similarly situated, but the different treatment of the providers did not violate the dormant Commerce Clause because both providers services were interstate in nature. Petition for a writ of certiorari filed on September 12,

46 CSX Aftermath Disparity Permissible in Alabama & Tennessee In March 2015, the US Supreme Court held that a tax disparity is permissible under the 4-R Act if the competitors are subject to another roughly comparable tax from which the rail carrier is exempt or if the state offers another sufficient justification. Alabama: On remand, the district court found that Alabama did not force rail carriers to use dyed diesel and sales tax and fuel-excise tax paid by motor carriers were roughly equivalent to tax paid by rail carriers, and thus Alabama s tax scheme did not violate 4 R Act. On April 14, 2017, taxpayer appealed. CSX Transp., Inc. v. Ala. Dep t of Revenue, No. 2:08-cv AKK, 2017 WL (N.D. Ala. 2017), appeal filed, No (11th Cir. Apr. 14, 2017). Tennessee: State s imposition of a 7% sales tax on railroad fuel purchases, while motor carriers pay an 18.4% excise tax, is found not discriminatory. Ill. Cent. R.R. Co. v. Tenn. Dep't of Revenue; No. 3:10-cv-00197, 2017 WL (M.D. Tenn. 2017), appeal filed, No (6th Cir. May 15, 2017). 46

47 Taxpayers 1st Amendment Right to Pass Through Fees Expressions Hair Design v. Schneiderman, 137 S.Ct (Mar. 29, 2017) In a unanimous ruling, the US Supreme Court ruled that a New York statute, which prohibits identifying a surcharge to customers for credit card payments, regulates speech and is therefore subject to heightened scrutiny. The case is remanded for the Second Circuit to determine whether New York s statute violates the First Amendment. Decision likely implicates state and local tax laws that either prohibit, or require, taxpayers to identify taxes and fees in customer invoices. 47

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50 Contact us Carley A. Roberts Partner Capitol Mall Suite 2500 Sacramento, CA Liz S. Cha Associate Sixth Street, NW Suite 700 Washington, DC stateandlocaltax.com eversheds-sutherland.com 2017 (US) LLP All rights reserved. This communication cannot be used for the purpose of avoiding any penalties that may be imposed under federal, state or local tax law.