Masha chairs Fredrikson’s Tax Disputes and Litigation Group. She represents public and private companies, trusts, estates and high-net-worth individuals in complex tax disputes. She handles all stages of tax controversies – voluntary disclosures, audits, administrative appeals, tax court, district court and appellate litigation.
Her experience includes resolving and litigating numerous types of tax disputes:
- State Corporate Income and Franchise Taxes, including nexus and Public Law 86-272, combination, business versus non-business income, allocation and apportionment issues (including sales factor sourcing), and credits (e.g., R&D, JOBZ, etc.);
- Sales and Use Taxes, including nexus, taxation of goods and services (e.g., digital goods, computer software, software as a service, telecommunication services, sales of electricity, advertising, prepared food), bundled transactions, sales for resale, “sales price” (e.g., cost of goods sold, services necessary to complete the sale, delivery charges, discounts, consideration received from third parties), sourcing, exemptions (e.g., qualified data center, manufacturing/industrial production, capital equipment, advertising, occasional sales, waste management, purely public charities), qui tam actions, and voluntary disclosures;
- Federal and International Tax Disputes, including audits and appeals involving the Global High-Net Worth initiative, offshore foreign financial asset disclosures, section 469 passive/non-passive income and losses, and section 183 hobby losses;
- Real and Personal Property Taxes, including state-assessed property (railroads, pipelines, utilities) and exempt property (public hospitals, hospital districts, clinics, nursing homes, churches, and institutions of purely public charity);
- Other State and Local Taxes, including MinnesotaCare Tax, Insurance Premiums Tax, Withholding Taxes (including worker classification), Tobacco Products Tax, and Minneapolis Entertainment Tax;
- State Individual Income Tax, including audits and appeals involving residency changes, personal and officer liability, criminal tax matters, section 469 passive/non-passive income and losses, and section 183 hobby losses.
Masha serves clients from a variety of industries, including retail, product distribution, manufacturing, financial services, insurance, aerospace, computer software, energy, healthcare, telecommunications, aerospace/automotive, hotel, cooperatives, restaurants, and entertainment.