Alysse McLoughlin, a partner in the Tax Practice Group in the New York office, was quoted in the article “New York Appeals Court Denies IBM’s Royalty Exclusion,” published by TaxNotes on March 16, 2023. The article covers IBM Corp. v. Tax Appeals Tribunal and the New York Supreme Court’s ruling that IBM improperly excluded royalty income payments from foreign affiliates when calculating its net income. Alysse explained the burden on taxpayers to prove that a tax does not fairly apply economic activity to the taxing state, especially when the company at issue is headquartered in that state.