Overview
Richard C. Call focuses his practice on a broad range of state and local tax matters, including litigation, advisory, and transactional work. He represents clients in proceedings before administrative bodies, trial courts, and appellate courts across multiple jurisdictions.
Corporate Income Tax Litigation and Transactions: Richard has significant experience with all major areas of corporate income tax, advising clients on complex issues such as nexus, apportionment, addbacks, transfer pricing, and combination . He represents clients on transfer pricing and alternative apportionment issues in various states, including Alabama, Louisiana, and South Carolina. He also regularly works with clients to evaluate and efficiently structure state income and franchise tax related to mergers, acquisitions, and other strategic transactions.
Sales Taxes and Company Business Models: Richard advises clients on sales tax issues that are affecting their overall business models, helping companies structure transactions to mitigate sales tax exposure, which often results in significant savings. As states increasingly expand the taxation of software, digital products, and services, he assists companies in identifying and managing their exposure to such taxes, particularly in advance of mergers, acquisitions, and other liquidity events.
Personal Income Tax Residency: Richard routinely advises clients on residency for various states, including New York, Massachusetts, California, and Illinois
Speeches and Publications: Richard frequently speaks on state and local tax issues and has presented before organizations such as the NYU SPS Annual Institute on State and Local Taxation, the Council On State Taxation, the Tax Executives Institute, and the Practising Law Institute. He also publishes frequently on state and local tax topics, with articles appearing in several publications, including Tax Notes State, Bloomberg BNA Weekly State Tax Report, Bloomberg BNA Multistate Tax Report, Tax Executive, Journal of State Taxation, Boston Business Journal, and NYU SPS Annual Institute on State and Local Taxation.
Results
- Successfully led a team seeking federal review of a New York City Unincorporated Business Tax case in 2025, arguing that the Tax Injunction Act did not bar federal review due to a lack of judges at the New York City Tax Appeals Tribunal, Administrative Judge Division
- Successfully argued before the Massachusetts Appeals Court in Bay State Gas Company v. Commissioner, securing a rare reversal of the Massachusetts Appellate Tax Board in a corporate income tax case
Recognitions
- Best Lawyers in America, Tax Law, Boston, 2022–2026
- Massachusetts Lawyers Weekly, Go To Tax Lawyer, 2024
- Legal 500 US, 2021–2024
- Super Lawyers, New York-Metro Rising Star, 2013–2014
- Super Lawyers, Massachusetts Rising Star, 2018
Credentials
Education
New York University School of Law, LLM, 2007
Brigham Young University, JD, 2006
Brigham Young University, BA, 2002
Admissions
Massachusetts
New York
