Topic
Combined Reporting
55 published works
SALT Shaker
Moving into Worldwide Waters? States Reaching Beyond the Water’s-Edge
By Maria Todorova, Justin Brown, Eversheds Sutherland SALT
Many states require or permit affiliated businesses to report their income to the state in a combined group return. In their article for Bloomberg Tax, Eversheds Sutherland attorneys Maria Todorova, Justin…
The SALT Lawyer
Combined Reporting Coming to New Jersey-The Good, The Bad and Other Policy Issues
Since Governor-Elect Murphy is set to take office later this month, we thought it would be instructive to offer up a brief primer and some additional thoughts on the new…
SALT Insights
“It’s Not You, It’s Me” – Agilent Technologies and the Inclusion of Foreign Holding Companies in Combined Corporate Income Tax Returns
In the famous Seinfeld episode titled "The Lip Reader," George Costanza's girlfriend breaks up with him by telling him "It's not you, it's me." George famously replied, "You're giving me…
SALT Shaker
Colorado Court of Appeals Held that Out-of-State Holding Company is Not Included in Combined Report
By Samantha Trencs and Eric Coffill The Colorado Court of Appeals held that a corporate parent doing business in Colorado was not required to include its subsidiary holding company that…
SALT Shaker
Minnesota Supreme Court Respects Federal Check-the-Box Election for Minnesota Combined Reporting Purposes
By Samantha Trencs and Jeff Friedman The Minnesota Supreme Court respected a foreign entity’s federal check-the-box election for the purpose of determining which entities were included in the Minnesota combined…
SALT Shaker
Check Your Michigan Unitary Group Filings–LaBelle Is Final
Last week, the Michigan Department of Treasury issued a Notice to Taxpayers explaining its approach in administering the now final Michigan Court of Appeals decision in LaBelle Management, Inc. v.…
SALT Shaker
Harley Hits Another Trial Court Road Bump–California Superior Court Upholds FTB’s Different Combined Reporting Treatment of Interstate and Intrastate Companies
By Robert Merten and Madison Barnett The San Diego County Superior Court determined that California’s combined filing regime—which requires interstate taxpayers to use combined reporting but permits intrastate taxpayers to…
SALT Shaker
NYC Tax Appeals Tribunal Holds Subsidiary Not Required to Be Included in Banking Corporation Tax Return
By Charles Capouet and Madison Barnett The New York City Tax Appeals Tribunal held that a bank filing a combined New York City bank tax return properly excluded from its…
Inside SALT
California FTB to Discuss Apportionment of Combined Group Income
The California Franchise Tax Board (FTB) will hold a second Interested Parties Meeting at their office in Rancho Cordova on April 20, 2016, dealing with the apportionment of income for…
SALT Shaker
Holding Company Gets Factored Out of Parent’s Colorado Combined Return on the Reg.
By Todd Betor and Eric Coffill On January 20, a Denver trial court ruled that Agilent Technologies World Trade, Inc. (World Trade), a holding company with no property or payroll…