Brent K. Beissel

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Brent Beissel is an associate in Reed Smith's State Tax Group. He focuses his practice on state tax planning and controversy matters, concentrating on income/franchise and sales and use taxes, with a particular focus on emerging technologies. Brent has worked on several significant Massachusetts appeals, and frequently co-authors and contributes to Reed Smith's Massachusetts publications and client alerts.

Latest Articles

On April 23, 2019, Reed Smith’s Massachusetts tax team held a webinar discussing issues and opportunities that arise under the net worth measure of the Massachusetts corporate excise tax.  The program, titled “Massachusetts’ Net Worth Based Tax – Not As Simple As It Appears”, ran about 35 minutes and included discussion on how the net worth measure is computed, some common taxpayer pitfalls in computing the tax, refund opportunities, and challenges to Department audit positions.…
The Massachusetts Appellate Tax Board (“ATB”) has—on its own motion—reconsidered and reversed a 2017 decision that denied refund claims for sales tax paid on software downloaded onto servers located in Massachusetts, but used outside of Massachusetts. Taxpayers that paid Massachusetts sales tax on software used outside the Commonwealth may have a refund opportunity and should consider protective refund claims. For full coverage, see our client alert here.…
Corporations and financial institutions that hold REMIC residual interests may have a Massachusetts corporate excise tax refund opportunity. REMICs are essentially pools of mortgages that are taxed on a pass-through basis for federal income tax purposes. Interests in REMICs fall into two general categories: regular interests and residual interests.  Typically, the holders of the REMIC residual interests are not entitled to any payments with respect to their interests until the regular interests have been fully…
Corporations and financial institutions that hold REMIC residual interests may have a Massachusetts corporate excise tax refund opportunity. REMICs are essentially pools of mortgages that are taxed on a pass-through basis for federal income tax purposes. Interests in REMICs fall into two general categories: regular interests and residual interests.  Typically, the holders of the REMIC residual interests are not entitled to any payments with respect to their interests until the regular interests have been fully…
Corporations and financial institutions that hold REMIC residual interests may have a Massachusetts corporate excise tax refund opportunity. REMICs are essentially pools of mortgages that are taxed on a pass-through basis for federal income tax purposes. Interests in REMICs fall into two general categories: regular interests and residual interests.  Typically, the holders of the REMIC residual interests are not entitled to any payments with respect to their interests until the regular interests have been fully…
Corporations and financial institutions that hold REMIC residual interests may have a Massachusetts corporate excise tax refund opportunity. REMICs are essentially pools of mortgages that are taxed on a pass-through basis for federal income tax purposes. Interests in REMICs fall into two general categories: regular interests and residual interests.  Typically, the holders of the REMIC residual interests are not entitled to any payments with respect to their interests until the regular interests have been fully…
Can a Department of Revenue auditor reduce a taxpayer’s deduction for a net operating loss (“NOL”) carryforward, even if the NOL was generated in a tax year that is closed under the statute of limitations? This question is the subject of an appeal currently pending at the ATB. The appeal involves a telecommunications company that was audited for the 2007 – 2009 tax years. The taxpayer had an NOL carryforward that it applied to reduce…
Can a Department of Revenue auditor reduce a taxpayer’s deduction for a net operating loss (“NOL”) carryforward, even if the NOL was generated in a tax year that is closed under the statute of limitations? This question is the subject of an appeal currently pending at the ATB. The appeal involves a telecommunications company that was audited for the 2007 – 2009 tax years. The taxpayer had an NOL carryforward that it applied to reduce…
Can a Department of Revenue auditor reduce a taxpayer’s deduction for a net operating loss (“NOL”) carryforward, even if the NOL was generated in a tax year that is closed under the statute of limitations? This question is the subject of an appeal currently pending at the ATB. The appeal involves a telecommunications company that was audited for the 2007 – 2009 tax years. The taxpayer had an NOL carryforward that it applied to reduce…