unitary reporting group

As part of a sweeping law change, New York will require taxpayers to use a water’s-edge combined reporting method when filing corporate income tax returns beginning January 1, 2015.

In this edition of A Pinch of SALT, Sutherland tax attorneys Carley A. Roberts, Pilar Mata, Stephanie Do and Kathryn E .Pittman explore California’s rich regulatory,

The California Board of Equalization (BOE) recently issued a decision holding that dividends received by an out-of-state corporate taxpayer were business income because the dividend payor played an integral and operational role in the taxpayer’s unitary business.  The BOE also denied the taxpayer’s dividends received deduction (DRD) under Cal. Revenue & Tax Code (R&TC) § 24402Appeal of Rio Doce Ltd., No. 402204 (Cal. Bd. of Eq. Nov. 17, 2010) (released Jan. 17, 2011).Continue Reading California Double Whammy: Dividends Are Apportionable Income, Not Deductible