On September 18, 2014, the New York State Tax Appeals Tribunal decided its first combination case addressing the 2007 changes to New York’s combined reporting regime: Matter of Knowledge Learning Corporation and Kindercare Learning Centers, Inc. Reversing a prior determination by an Administrative Law Judge, the Tribunal held that the taxpayers did indeed meet their burden of proving that combined reporting was proper by demonstrating the existence of substantial intercorporate transactions. The Tribunal’s decision provides guidance for taxpayers in determining the types of documents and testimony that can establish the existence of substantial intercorporate transactions and demonstrate that those transactions were entered into for valid business purposes and had economic substance.

View the full Legal Alert.