On November 17, 2014, the Appellate Tax Board released its Findings of Fact and Report in Genentech v. Commissionerwhich held that a pharmaceutical company qualified as a “manufacturer” under Massachusetts law, and was required to apportion its corporate excise tax base using the single sales factor formula for manufacturing corporations, instead of the three factor formula.

Genentech produces medicines using genetically modified cells.  It argued that its activities were not manufacturing, analogizing them to a […]

Recently the ATO attempted to reassure taxpayers by stating that declaring overseas income under Project DO IT would not result in a ‘red flag’ against their names. The deadline to access the ATO amnesty is 19 December 2014.

We have prepared a number of disclosures for taxpayers with bank accounts and other income to declare from overseas sources. We have managed disclosures for taxpayers with special circumstances by agreeing on particular action plans with the […]