Law360 Covers Robinson Bradshaw's Amicus Brief in Tax DisputePDF
Robinson Bradshaw attorneys filed an amicus brief in the U.S. Supreme Court on behalf of a group of tax law professors regarding state taxation of trusts. Erik R. Zimmerman, Mark A. Hiller and Gabriel Wright represented the professors, along with Daniel Hemel of the University of Chicago Law School.
The amicus brief addresses important issues at the intersection of constitutional law and tax law. The Supreme Court is considering whether the Due Process Clause of the 14th Amendment permits North Carolina to tax out-of-state income earned by a trust with in-state beneficiaries. As stated in a recent Law360 Tax Authority article, the professors argue that North Carolina can tax the trust's income because the trust "purposefully directs" its efforts at its beneficiaries in North Carolina—meaning that North Carolina has the "minimum contacts" with the trust that due process requires. The Court's resolution of these issues could have far-reaching consequences for state taxation of trusts across the country.
To read "Tax Profs Back NC in Supreme Court Trust Residency Spat," please visit Law360 Tax Authority. A subscription is required.