BankBoston Corp. v. Commissioner of Revenue

861 N.E.2d 450, 68 Mass. App. Ct. 156, 2007 Mass. App. LEXIS 101
CourtMassachusetts Appeals Court
DecidedFebruary 2, 2007
DocketNo. 05-P-1545
StatusPublished

This text of 861 N.E.2d 450 (BankBoston Corp. v. Commissioner of Revenue) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BankBoston Corp. v. Commissioner of Revenue, 861 N.E.2d 450, 68 Mass. App. Ct. 156, 2007 Mass. App. LEXIS 101 (Mass. Ct. App. 2007).

Opinion

Grainger, J.

When is a dividend not a dividend, or at least not treated as one for purposes of the corporate excise tax, G. L. c. 63? This issue is presented in the context of State and Federal measures intended to level the field of opportunity in real estate investment.

BankBoston Corporation (bank) appeals from a decision of the Appellate Tax Board (board) upholding the Commissioner of Revenue’s (commissioner) determination that distributions of a real estate investment trust (REIT) to a corporate shareholder were subject to the corporate excise tax for 1996 and 1997, the years in question. We conclude that the board’s decision is solidly based on the well-established principle of uniform ap[157]*157plication of tax provisions, both within the statutes of the Commonwealth and between Massachusetts and Federal law, absent apparent contrary legislative intent. In addition, the board’s decision follows the customary imposition of tax liability at a single point within corporate enterprises, and is consistent with the purpose underlying the creation of REITs. Accordingly, we affirm.

Background. In 1960, Congress, with encouragement and prompting from the investment and money management industry, created REITs as another variation of so-called “pass-through” entities such as mutual funds and Subchapter S corporations. These constructs of Federal law are intended to provide access for individuals of moderate means to investments that had previously been out of reach due to economies of scale and tax considerations. H.R. Conf. Rep. No. 94-658 at 353 (1976), reprinted in 1976 U.S.C.C.A.N. 2897, 3249-3250. Congress determined that the usual imposition of tax on revenues when they are earned by REITs, and then again on those same earnings when they are distributed to individuals as dividends, amounted to unfair double taxation in the case of pass-through entities, where the investment entity was no more than the structural alter ego of the shareholders. For this reason, REITs achieve pass-through status for tax purposes via a special “dividends-paid” deduction, by which they can deduct from their own income the amount that they pay out to their beneficial owners. See 26 U.S.C. § 857(b)(2)(B) (2000).

REITs quickly attracted not only individuals of moderate means, but also sophisticated investors. Corporations, including bank holding companies,1 perceived that the dividends-paid deduction enjoyed by REITs might in theory be combined with the so-called dividends-received deduction normally enjoyed by corporate parents.2 The combination of these two deductions creates the issue in this case, where the recipient of the REIT’s [158]*158distribution is itself a corporation. If a recipient corporation may invoke the usual dividends-received deduction for earnings paid to it by a REIT subsidiary, then the earnings would entirely escape taxation at the corporate level, because the REIT has already claimed the dividends-paid deduction on the same earnings. Congress closed this loophole by language that specifically denied REIT distributions “dividend” status for purposes of the dividends-received deduction. 26 U.S.C. § 243(d)(3) (2000).3 Federal law thus imposes uniformity in the Federal taxation of earnings of corporate subsidiaries. Tax is paid, but only paid once, by the corporate family whether or not the subsidiary is a REIT. REIT distributions are taxed to the parent company to compensate for the dividends-paid deduction exempting REITs, while other distributions are taxed to the subsidiaries to compensate for the dividends-received deduction exempting the parent.

The Massachusetts corporate excise tax, G. L. c. 63, also recognizes that corporate revenues should be taxed only once regardless of subsequent transfers from subsidiary to parent. This goal is achieved through a somewhat more complicated three-step process not utilized by the Internal Revenue Code (Code).4 At the conclusion of this process, the Massachusetts corporate taxpayer enjoys a deduction for dividends received [159]*159from its subsidiaries essentially equivalent to that provided by the Code.* ***5 Unlike the Code, Massachusetts tax law contained no explicit reference to REITs during the tax years here at issue.6 The dispute between the parties may be summarized as a disagreement whether Massachusetts law treated REIT distributions to a corporate shareholder in the same way as the Code during the years in question, despite the lack of explicit language providing for such treatment within the confines of G. L. c. 63.

Discussion. The commissioner asserted, and the board agreed, that G. L. c. 63 must be administered consistent with the definition of “dividend” provided for income tax purposes in G. L. c. 62, and consistent with Federal taxation of REITs. Reference to G. L. c. 62 presents the clear advantage of avoiding inconsistency between two chapters of the General Laws, both governing taxation. And, because G. L. c. 62 itself defines “dividend” by reference to the Code, it extends uniformity to Federal tax law at the same time. Specifically, it defines as “ ‘[dividend’, any item of Federal gross income which is treated as a dividend under the provisions of the Code.” G. L. c. 62, § (l)(e), as amended through St. 1989, c. 287, § 46.

As stated above, the intended beneficiaries of REITs were individuals, not corporations already entitled to a dividends-received deduction. Consequently, the fundamental REIT structure, incorporating a single taxable event for the investor, required alteration when these unintended corporate beneficiaries with additional tax advantages entered the arena. The commis[160]*160sioner argues that this alteration, found in 26 U.S.C. § 243(d)(3), providing that REIT distributions to corporate shareholders shall “not be treated as dividends,” must be deemed also to be a part of Massachusetts law. This position is supported by the fact that the Legislature has not indicated that it intends to vary the treatment of REITs on a State level, and the Supreme Judicial Court “has consistently adhered to the meaning of Federal tax language incorporated into our tax law where no contrary legislative intent is apparent.” Commissioner of Rev. v. Franchi, 423 Mass. 817, 823 (1996).

Both parties rely on two leading cases, Commissioner of Rev. v. Northeast Petroleum Corp., 401 Mass. 44 (1987) (Northeast Petroleum II),7 and Dow Chem. Co. v. Commissioner of Rev., 378 Mass. 254 (1979) (Dow Chemical). These cases are instructive in that both dealt with a subsidiary’s distributions that were not the usual type of dividends issued to a parent company. Consequently each decision set forth principles for determining whether a distribution qualified as a “dividend” and was therefore deductible under G. L. c. 63, which contained no definition of the term. The bank points to examples of deductions that were allowed despite the fact that, as in this case, they were precluded by the Code.

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Bluebook (online)
861 N.E.2d 450, 68 Mass. App. Ct. 156, 2007 Mass. App. LEXIS 101, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bankboston-corp-v-commissioner-of-revenue-massappct-2007.