Topic
Combined Reporting
55 published works
Inside SALT
Connecticut Limits New Tax Haven Law
By Nick Furtwengler, Richard C. Call, Scott M. Susko
In June of 2015, Connecticut passed legislation that implements combined reporting for tax years beginning on, or after January 1, 2016. Part of the new regime, which is codified by…
Inside SALT
A Steep Slope — Vermont Supreme Court Finds AIG Not Unitary With a Ski Resort Based On a Clear and Cogent Evidence Burden of Proof
By Arthur R. Rosen, Richard C. Call
In the first Vermont Supreme Court decision addressing combined unitary reporting since Vermont’s combined reporting regime became effective in 2006, the court affirmed a lower court’s decision that AIG, the…
Inside SALT
California’s Harley-Davidson Decision Rides over Nexus Lines
On May 28 2015, The California Court of Appeals issued a decision in Harley-Davidson, Inc. v. Franchise Tax Board, 187 Cal.Rptr.3d 672; and it was ultimately about much more than…
SALT Shaker
The Sun Shines on Taxpayers: New York State Tax Appeals Tribunal Grants Appeal in Combined Reporting Case
By Nicole Boutros and Andrew Appleby In yet another taxpayer victory, the recently reconstituted New York State Tax Appeals Tribunal determined that the New York State Department of Taxation and…
Inside SALT
A Year’s Review of Massachusetts Tax Cases
By Scott M. Susko, Richard C. Call
Allied Domecq Spirits & Wines USA, Inc. v. Comm’r of Revenue, 85 Mass. App. Ct. 1125 (2014) In a unique case, the Massachusetts Appeals Court affirmed a ruling of the…
Cooking with SALT
Louisiana House Ways & Means Committee to Discuss Combined Reporting, Add-Backs, NOL Carrybacks, and Refundable Tax Credits
By Matt Mantle
Everyone should get ready for a very busy Monday at the Louisiana Legislature! On Monday, April 27th, at 9:00, the Louisiana House Ways & Means Committee will meet to discuss a…
Inside SALT
District of Columbia’s Transfer Pricing Enforcement Program and Combined Reporting Regime: Taking Two Bites of the Same Apple
By Stephen P. Kranz, Diann Smith, McDermott Will & Emery
In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly…
Inside SALT
Decoding Combination: What Is a Unitary Business
This article is the first of our new series regarding common issues and opportunities associated with combined reporting. Because most states either statutorily require or permit some method of combined…
Inside SALT
New York State Tax Department Releases Guidance on Tax Reform Legislation
The New York State Department of Taxation and Finance (the Department) has been issuing guidance explaining the 2014 corporate tax reform legislation (generally effective on January 1, 2015) through a…
Inside SALT
Inside the New York Budget Bill: Combined Reporting
The New York Legislature has passed bills related to the 2015–2016 budget (S2009-B/A3009-B and S4610-A/A6721-A, collectively referred to herein as the Budget Bill) containing several significant “technical corrections” to the…