Legal Opinion
The First Marblehead Corp. v. Commissioner of Revenue
Massachusetts Supreme Judicial Court
Decided August 12, 2016No. SJC 11609Published
1Opinion of the CourtBotsford, J.
In The First Marblehead Corp. v. Commissioner of Revenue, 470 Mass. 497, 498 (2015) (First Marblehead), this court affirmed a decision of the Appellate Tax Board (board) concerning the tax liability of the taxpayer GATE Holdings Inc. (Gate), under the Commonwealth’s financial institution excise tax (FIET). Gate was a wholly owned subsidiary of The First Marblehead Corporation (FMC), 3 id. at 497-498, and “played an integral role in the FMC student loan securitization process,” as the holder of beneficial interests in all the separate trusts that effectively owned the securitized student…
2Cases cited5 opinions
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Oklahoma Tax Commission v. Jefferson Lines, Inc.Supreme Court of the United States · 1995
- Comptroller of Treasury of Md. v. WynneSupreme Court of the United States · 2015
- First Marblehead Corp. v. Mass. Comm'r RevenueSupreme Court of the United States · 2015
- The First Marblehead Corporation v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 2015