The Massachusetts Supreme Judicial Court recently held in The First Marblehead Corporation v. Commissioner of Revenue (“First Marblehead II”), 475 Mass. 159 (2016), that securitized loans of GATE Holdings Inc. (“Gate”) were properly sourced to Gate’s commercial domicile in Massachusetts for purposes of computing Gate’s property factor for Massachusetts financial institutions excise tax (“FIET”) purposes, and that the FIET, as applied to Gate, satisfies the internal consistency test.