combined reporting

Subscribe to combined reporting via RSS

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…

By Stephen Burroughs and Andrew Appleby

A Vermont Superior Court held that the Commissioner of Taxes unconstitutionally applied the unitary business principle to AIG and its subsidiary, Stowe Mountain Resort. Stowe operates a ski resort, lodging and conference business in Vermont. None of AIG’s other 700 subsidiaries resemble a ski resort, and the Commissioner acknowledged…

Sutherland’s state and local tax team will host the Sutherland SALT Roundtable Silicon Valley on Tuesday, June 17 at the Sofitel San Francisco Bay in Redwood City, California. The roundtable will take an in-depth look at significant state and local tax issues and developments impacting the technology sector, including:

  • Digital Unrest – Legislation, Litigation and

…

In their article for State Tax Notes, “Heads They Win, Tails You Lose: New York Decombination and Discretionary Adjustments,” Sutherland attorneys Marc A. Simonetti, Andrew D. Appleby and Sahang-Hee Hahn assert that the New York State Department of Taxation and Finance applies its combined reporting and discretionary authority provisions arbitrarily to maximize its tax…

By Ted Friedman and Andrew Appleby

The Indiana Department of Revenue determined that an audit correctly required a distribution and manufacturing subsidiary of a tobacco company to file a combined return with its corporate affiliates. The Audit Division concluded that the subsidiary’s income, as reported, did not fairly reflect its Indiana source income because of…

Sutherland’s state and local tax team will host the Sutherland SALT Roundtable Silicon Valley on Tuesday, June 17 at the Sofitel San Francisco Bay in Redwood City, California. The roundtable will take an in-depth look at significant state and local tax issues and developments impacting the technology sector, including:

  • Digital Unrest – Legislation, Litigation and

…

By Derek Takehara and Pilar Mata

The Magistrate Division of the Oregon Tax Court held that for the tax year 2003, (1) Rent-A-Center, a rent-to-own operator, and its wholly-owned franchising subsidiary, ColorTyme, were not unitary; (2) ColorTyme did not have nexus with Oregon; and (3) Rent-A-Center and its captive insurance subsidiary, Legacy Insurance Co. (Legacy)…

The New York State Governor and Legislature recently enacted the 2014-2015 New York State Budget, Senate Bill 6359-D and Assembly Bill 8559-D (Budget), which results in the most significant overhaul of New York’s franchise tax on corporations in decades. In this edition of New York Tax Reform Made Easy, we will address the creation of the Prior Net Operating Loss deduction.
Continue Reading New York Tax Reform Made Easy: Net Operating Loss

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…