By Nicole Boutros and Timothy Gustafson
A New York State Division of Tax Appeals Administrative Law Judge (“ALJ”) upheld the denial of corporation franchise tax refund claims, determining the taxpayers were not engaged in a unitary business. The taxpayers and their subsidiaries (“Group”) provided services in what the ALJ found were “similar and related lines
By Ted Friedman and Timothy Gustafson
The Supreme Court of Missouri reversed and remanded a decision of the Administrative Hearing Commission (see our coverage of the Commission’s January 28, 2013 decision here) and held that income from a “rabbi trust”—a trust established by a corporation to fund a nonqualified deferred compensation plan for company
By Zachary Atkins and Andrew Appleby
A New York appellate court held that the Department of Taxation and Finance could not retroactively apply a 2010 amendment to the Tax Law to a transaction entered into by a Florida couple nearly four years earlier. The nonresident taxpayers sold their stock in an S-corporation to a third
By Sahang-Hee Hahn and Timothy Gustafson
The Indiana Department of Revenue required an out-of-state clothing company and its subsidiary to file a combined Indiana corporate income tax return, determining that the taxpayer’s transfer pricing study was insufficient to establish that its intercompany transactions were conducted at arm’s length. The taxpayer was the parent of a
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By Ted Friedman and Prentiss Willson
The Indiana Department of Revenue determined that affiliated entities of an out-of-state manufacturing corporation were not unitary. The corporation conducted marketing operations as one business segment and production operations as a second business segment. The corporation included its marketing entities in its Indiana consolidated return. On audit, Department staff
By Stephanie Do and Andrew Appleby
The Indiana Department of Revenue determined that an out-of-state wireless communications equipment wholesaler’s in-state business activities were protected by P.L. 86-272, and therefore, the wholesaler did not have nexus for Indiana corporate income tax purposes. The wholesaler’s in-state activities were limited to shipping products to Indiana customers by common
By Nicole Boutros and Pilar Mata
The Texas Comptroller determined that a taxpayer’s “digitizing” services provided to oil and gas industry clients were taxable data processing services for Texas sales and use tax purposes. The services at issue consisted of taking well log data from the client; analyzing, manipulating and interpreting such data; and providing
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We hope you enjoy this very special edition of the Sutherland SALT Shaker newsletter.
In this issue:
