corporate franchise tax

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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.…

The DC Court of Appeals upheld the DC Office of Tax and Revenue’s (OTR) determination that the incorporated owner of substantially all of a high technology partnership was not entitled to claim qualified high technology company (QHTC) benefits generated by the partnership.

The partnership at issue qualified for DC QHTC tax incentives. One of the…

On August 9, 2023, the New York State Department of Taxation and Finance (Department) submitted its draft corporate franchise tax regulations for publication in the State Register – a significant and necessary step in the State Administrative Procedure Act (SAPA) process to formally adopt regulations related to the sweeping reform of the state’s Corporation Franchise…

On February 24, 2023, the Wisconsin Tax Appeals Commission upheld the Department’s assessment that Skechers’ licensing transaction with its wholly owned subsidiary, Skechers USA Inc. II (SKII), lacked a valid business purpose and economic substance. On the formation of SKII, Skechers entered into a license agreement with its subsidiary that generated significant royalty deductions, which…

On April 29, 2022, the New York State Department of Taxation and Finance issued two sets of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after January 1, 2015. Since the sweeping corporate tax reform was enacted, the Department has published a series of…