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Masha represents public and private companies, trusts, estates and high-net-worth individuals in complex tax disputes. She has handled all stages of tax controversies – voluntary disclosures, audits, administrative appeals, tax court, district court and appellate litigation.
Masha’s experience includes resolving and litigating numerous types of tax disputes:
Masha serves clients from a variety of industries, including retail, product distribution, manufacturing, financial services, insurance, computer software and hardware, energy, healthcare, telecommunications, aerospace/automotive, hotel, cooperatives, restaurants, entertainment and photographic equipment and supplies.
Masha works closely with our corporate and securities practices in assisting clients with multistate tax planning, advising clients on the state and local tax implications of corporate transactions, including multistate analysis of mergers and acquisitions to achieve state tax efficiencies (including nexus and apportionment issues), conducting due diligence investigations to uncover potential state tax liabilities, drafting state tax provisions in agreements to provide clients with proper protections and recourse regarding state taxes and conducting multistate surveys of the tax treatment of a wide variety of business activities, including drop shipment and dock sale transactions, advertising services, digital goods, software (including software as a service and cloud-based computing) and state thresholds for withholding taxes.
December 3, 2021
By Kenneth S. Levinson and Masha M. Yevzelman
If you are into Foreign Bank Account Reports (FBARs), your concern about penalties for failing to comply with those FinCEN 114 reporting rules just took an exciting, and perhaps fearsome, turn.
November 11, 2021
For years, remote workers had been complicating state tax compliance for companies. When the U.S. Supreme Court’s decision in Wayfair came out in June 2018, many believed that the decision’s economic nexus standards would reduce complexity surrounding remote workers.
August 12, 2021
Since 1959, taxpayers have been relying on a federal law—Public Law 86-272—to protect them from having to file state income tax returns in states where the taxpayers’ in-state activities are limited to just soliciting sales of tangible personal property. On August 4, 2021, the Multistate Tax Commission (MTC) member states voted 20-0 to revise the MTC’s “Statement of Information” regarding Public Law 86-272 in an attempt to eviscerate the federal law’s protections.
June 3, 2021
Minnesotans are wondering: could or should they change their residency to achieve income tax savings?
November 17, 2020
The Minnesota Department of Revenue has updated its data center exemption guidance, taking a step in the right direction for purchases of distributed software and required documentation.
April 22, 2020
By Masha M. Yevzelman and David B. Tibbals
As social distancing methods and shelter-in-place orders during the COVID-19 pandemic have prompted many across the country to work from home, businesses have begun to wonder about the nexus ramifications of their newly-expanded telecommuting arrangements.
March 21, 2020
By Kenneth S. Levinson, Masha M. Yevzelman, David B. Tibbals and Karen Sandler Steinert
COVID-19 has had innumerable impacts on our daily lives. In response, the IRS and certain local states have provided guidance for taxpayers whose federal income tax returns are due on April 15.
September 10, 2018
Individuals or companies with undisclosed foreign financial assets or income have until September 28, 2018 to enter the IRS’s Offshore Voluntary Disclosure Program.
June 22, 2018
By Masha M. Yevzelman & Thomas R. Muck
A merchant of goods and services that makes sales in multiple states is no longer required to have physical presence in a state in order to be subject to sales and use tax in that state.
September 1, 2017
Effective for tax years beginning after December 31, 2016, a “financial institution” for Minnesota tax purposes includes both corporations and “other business entities,” such as limited liability companies, that perform financial institution activities.
June 1, 2017
Should keeping a bank account or financial adviser in Minnesota be considered when determining where a person is a resident?
May 31, 2017
By Masha M. Yevzelman & Thomas R. Muck
When evaluating whether an individual is a Minnesota resident, the Minnesota Department of Revenue has been considering, among many factors, the location of a person’s attorney, accountant, financial adviser and bank accounts.
December 1, 2016
Financial institutions have not been shy about challenging Minnesota Department of Revenue tax determinations in court. For example, in the 1980s and early 1990s, the banking industry prevailed against the state’s unconstitutional imposition of the bank excise tax. Then, in 1998, Firstar Corporation (headquartered in Wisconsin) convinced the Minnesota Supreme Court that, for purposes of the corporate franchise tax, the bank’s sale of an office building in Wisconsin was “nonbusiness income” taxable only in Wisconsin, rather than “business income” apportioned among several states, including Minnesota.
February 1, 2011
Since 1970, the Bank Secrecy Act has required U.S. persons who have in aggregate more than $10,000 in foreign financial accounts to report certain information about those accounts to the Department of the Treasury using Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR).
