Most separate reporting states give the department of revenue discretionary authority to require affiliated companies to file a combined return under certain conditions. This authority can be a valuable when applied fairly and appropriately but can cause significant problems when abused. In this A Pinch of SALT, Sutherland SALT attorneys Jonathan Feldman and Madison Barnett use the recent “trials” and tribulations in North Carolina as a case study to illustrate the manner in which a state’s authority should be exercised.


Read “Using the Force to Combine in Separate Return States,” reprinted with permission from the September 5, 2011 issue of State Tax Notes.