statute of limitations

We previously reported on a significant taxpayer victory in which the Oregon Tax Court held that changes or corrections made by other states’ taxing authorities will not hold open the Oregon statute of limitations. Dep’t of Revenue v. Washington Federal, Inc., TC 5010 (Or. Tax Ct., June 29, 2012). As promised, following is our analysis of the case.

The taxpayer, a multistate federal savings and loan corporation, timely filed its Oregon corporate excise tax returns for tax years 1999 through 2002. Arizona and Idaho state taxing authorities assessed the taxpayer in 2003 and 2006, respectively. In 2008, after the expiration of the standard Oregon statute of limitations for assessment (generally three years from the date the return was filed), the Oregon Department of Revenue (the Department) issued assessments for the tax years 1999 through 2002. The issue before the court was whether the Department’s assessments were timely.

Continue Reading Oregon DOR Out of Luck on SOL: Our Analysis

In an unusual case, the Oregon Department of Revenue tried to argue that a taxpayer’s receipt of an assessment from two other states held open the statute of limitations for Oregon income tax purposes. The Oregon Tax Court disagreed, holding that the assessment from another state would have to impact the taxpayer’s Oregon income tax

On Monday, Sutherland SALT Partner Jeff Friedman participated in a panel discussion titled “Waive or Walk: Considerations for Extending the Statute of Limitations,” at the Tax Executives Institute (TEI) 61st Annual Midyear Conference. The panel was moderated by Tov Haueisen from General Electric Company and Henry Orphys from Intel Corporation, and included Steven Rainey