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Massachusetts Tax Workshop – Defining and Applying Massachusetts Source Income for Non-Resident Individuals
When: March 20, 2024
Location: Boston Bar Association
 

16 Beacon Street
Boston, MA

People: Richard L. Jones and Caroline A. Kupiec

Richard Jones and Caroline Kupiec joined the panel discussion, "Massachusetts Tax Workshop - Defining and Applying Massachusetts Source Income for Non-Resident Individuals," at the Boston Bar Association's workshop on March 20, 2024.

The panelists explored Massachusetts’ regime for taxing income earned by non-resident individuals as set forth in Chapter 62, Section 5A of the Massachusetts General Laws (Section 5A). After a brief introduction to 5A, they delved into more complex fact patterns that tested common assumptions about Massachusetts-source income from compensation, C corporations, S corporations, partnerships, estates and trusts. They addressed Massachusetts’ default positions and challenges to those default positions as raised in recent Appellate Tax Board and Supreme Judicial Court cases on taxing the following categories of income:

  • Compensation for personal services and deferred compensation
  • Stock-based compensation (including exercise of stock options)
  • Sale of a business or an interest in a business