Earlier this year, the Supreme Court issued a unanimous opinion in the North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, holding that a trust beneficiary’s residence alone is not sufficient for a state to tax the trust’s undistributed income. Prior to the decision, some speculated that the Court’s decision could have far-reaching Due Process implications. However, the Court’s decision purported to be limited to the specific facts at issue – raising the question as to how (or if) Kaestner altered the Due Process landscape.
Michael has been a member of Reed Smith’s State Tax Group since 2013. He currently focuses his practice on Pennsylvania, Virginia, and New Jersey taxes, and unclaimed property. He represents clients in state tax return position evaluation, audit defense, administrative appeals, and litigation.
Megan is an associate in the state tax group. Megan specializes in multistate tax litigation matters, with a focus on Pennsylvania and North Carolina. Prior to joining Reed Smith, Megan worked as a Tax Consultant in PwC’s State and Local Tax Group in Philadelphia, where she worked on tax planning, controversy, and transactional matters for public, private, and non-profit companies. Megan also has significant experience with tax return preparation and compliance in both state income tax and indirect tax.
Excellent analysis of this case.
The material was presented in a concise and easily comprehensible manner.
Nice to hear about Int’l Shoe again. Like chatting with an old friend. Thanks!