Topic
Combined Reporting
55 published works
Inside SALT
Inside the New York Budget Bill: Guidance Released Regarding Transitional Compliance and Qualified New York Manufacturers
On March 31, 2014, Governor Andrew Cuomo signed into law a budget bill containing major corporate tax reform. That new law resulted in significant changes for many corporate taxpayers, including…
SALT Shaker
New Mexico Allows New Combined Reporting Group to Use NOL Carryforwards from Separate Filers
By Derek Takehara and Andrew Appleby The New Mexico Department of Taxation and Revenue granted a combined reporting group’s corporate income tax protest by allowing the group to claim a…
SALT Shaker
Has New York City Added a Fourth Element for Determining a Combined Group?
A New York Tax Appeals Tribunal Administrative Law Judge (ALJ) recently determined that a federal savings and loan association was not required to include a subsidiary, which was formed as…
Inside SALT
Yes, Distortion is Enough: New York Tax Appeals Tribunal Clarifies Combined Reporting Requirements
On September 18, 2014, the New York State Tax Appeals Tribunal released its first decision interpreting New York State’s post-2007 combined reporting laws and, in doing so, answered a question…
SALT Shaker
New York Tax Appeals Tribunal Reverses “Distorted” Knowledge Learning Decision and Provides Guidance for Proving Substantial Intercorporate Transactions
On September 18, 2014, the New York State Tax Appeals Tribunal decided its first combination case addressing the 2007 changes to New York’s combined reporting regime: Matter of Knowledge Learning…
Inside SALT
Allied Domecq: Nexus-Combined Reporting
By Diann Smith, Stephen P. Kranz
In Allied Domecq Spirits & Wines USA, Inc. v. Commissioner of Revenue, the Massachusetts Court of Appeals held that the parent company of a Massachusetts taxpayer could not be included…
SALT Shaker
Indiana Determines Combination Is Justified, But Alternative Methodology Must Be Considered
By Ted Friedman and Andrew Appleby The Indiana Department of Revenue determined that an audit correctly required a distribution and manufacturing subsidiary of a tobacco company to file a combined…
SALT Shaker
Rumor Has It: IT USA Wins on Decombination at New York Tax Appeals Tribunal
By Sahang-Hee Hahn and Timothy Gustafson The New York State Tax Appeals Tribunal ruled the New York State Department of Taxation and Finance could not decombine taxpayers’ New York combined…
SALT Shaker
No “Best Method” in the Madness: Taxpayer’s Transfer Pricing Study Fails to Stop Forced Combination in Indiana
By Sahang-Hee Hahn and Timothy Gustafson The Indiana Department of Revenue required an out-of-state clothing company and its subsidiary to file a combined Indiana corporate income tax return, determining that…
SALT Shaker
South Carolina Seeks to Clarify Use of Alternative Apportionment and Combined Reporting
By Zachary Atkins and Prentiss Willson The South Carolina Department of Revenue issued a draft revenue ruling that purports to clarify the use of alternative apportionment and combined reporting for…