Topic
Combined Reporting
55 published works
SALT Shaker
Take Control! Massachusetts Clarifies Common Ownership Requirement for Combined Reporting
By Christopher Chang and Timothy Gustafson The Massachusetts Department of Revenue issued a Letter Ruling stating that, for purposes of determining common control with regard to a combined report, the…
SALT Shaker
New York: Disallowance of Mandatory Combined Reporting Position Sustained
By Nicole Boutros and Andrew Appleby In a case of first impression interpreting when substantial intercorporate transactions are present for purposes of New York’s mandatory combined reporting provisions, a New…
Inside SALT
New York Issues First New Combined Reporting Law Determination—and It’s Not Pretty
Even though New York amended its combination statute for years beginning in 2007, we are just now beginning to see litigation related to those amendments. At the end of June…
SALT Shaker
D.C. Proposes to Extend Deadline for Combined Reports
As part of its implementation of mandatory combined reporting, the District of Columbia’s Office of Tax and Revenue issued a taxpayer-friendly proposed regulation that would provide an automatic seven-month extension…
SALT Shaker
A Pupu Platter of a Case: Packaging and Filtration Businesses Held Unitary
In a somewhat troubling decision, an Illinois Appellate Court held that a taxpayer’s parent company and its subsidiaries engaged in two lines of business—consumer packaging manufacturing and filtration product manufacturing—were…
SALT Shaker
Another Oregon Tax Court Decision Regarding Insurance Companies and Combined Reporting
The Oregon Tax Court issued its second decision in less than a month regarding combined returns that include an insurance company, this time finding for the taxpayer. Last month, in…
SALT Shaker
Indiana Combination Is Last Resort
The Indiana Tax Court granted a motion for partial summary judgment to AE Outfitters Retail Co. and held that the Indiana Department of State Revenue may require combined reporting only…
SALT Shaker
New York Attempts to Take Taxpayer Out Behind the (Kell)Woodshed
The New York State Department of Taxation and Finance (Department) provided another example of its longstanding eagerness to force taxpayer combination—at least in cases where it results in increased tax…
SALT Shaker
Who Lost the Remote?: Virginia Disallowed Losses and Combined Reporting
The Virginia Department of Revenue (i) applied its narrow interpretation of the State's related member add-back provision to disallow a taxpayer’s factoring company discount losses, and (ii) prohibited the taxpayer…
SALT Shaker
De-Combining Hoosiers
The Indiana Tax Court held that the Indiana Department of Revenue could not require Rent-A-Center East, Inc. (RAC East) to file a combined return with two of its affiliates. Rent-A-Center…