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In PENN Entertainment, Inc. v. Indiana Department of State Revenue, a unanimous Indiana Supreme Court reversed the tax court’s grant of summary judgment for the Indiana Department of Revenue requiring PENN Entertainment to add back approximately $2 billion in wagering excise taxes it paid to other states when calculating its Indiana adjusted gross income…

In a summary order issued May 20, 2026, the Supreme Court of Wisconsin declined to hear a petition for review filed by Skechers USA, Inc. (Skechers) concerning the Wisconsin Department of Revenue’s (Department) disallowance of corporate franchise tax deductions claimed for intercompany royalties. Justice Rebecca Bradley dissented but offered no written opinion explaining her reasoning.…

In a recent letter ruling, the Virginia Tax Commissioner granted a corporate taxpayer relief from Virginia’s intercompany interest add‑back requirement, concluding that the taxpayer satisfied the statutory business purpose exception.

The case arose from a centralized cash management structure in which subsidiaries deposited cash with the parent entity and relied on intercompany loans when they…

On February 26, 2024, the Alabama Tax Tribunal (Tribunal) held that Huhtamaki Inc. (Huhtamaki), a packaging manufacturer, is not required to add back interest payments indirectly made to foreign affiliates through a U.S. parent company.

Under Alabama’s add-back statute, a corporation must add back otherwise deductible interest expenses directly or indirectly paid to a related…

The New York State Tax Appeals Tribunal affirmed a New York State Division of Tax Appeals determination denying a refund claim to a taxpayer that sought to apply the income sourcing rules for registered broker-dealers to receipts from its separate investment advisory business. The taxpayer structured its broker-dealer operations and investment advisory operations into two…

On December 19, 2019, the New York Division of Tax Appeals (DTA) held that a corporate taxpayer must include royalties received from foreign affiliates in the computation of its entire net income for its 2007 through 2012 tax years. Matter of IBM Corp., DTA Nos. 827825, 827997, and 827998 (N.Y. Div. Tax App. Dec. 19…

The New Jersey Tax Court held that distributions made to a corporation’s two shareholders constituted dividends, and rejected the corporation’s argument that the distributions should be treated as compensation for managerial services that could be deducted for New Jersey Corporation Business Tax purposes. The Court explained that New Jersey has adopted the federal test to…

The Massachusetts Appellate Tax Board disallowed a deduction for Indiana utility receipts tax (URT) paid by a natural gas distribution operator with operations in Indiana. The deduction for the URT was disallowed, for purposes of computing Massachusetts net income for corporate excise tax, because the URT is not a deductible “transaction tax.” The Board found…