Courts have formulated more than a dozen legal canons of statutory construction specific to tax.
In the October 2024 installment of “A Pinch of SALT” in Tax Notes State, Eversheds Sutherland attorneys Jeff Friedman, John Ormonde and Kelly Donigan examine the application of statutory construction principles to conflicts involving allocation and apportionment statutes.
Because an income tax must contain an allocation and apportionment regime to comply with the due process and commerce clauses of the US Constitution, these regimes should be treated as imposition statutes and not exemptions or deductions.
Read the full article here.