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Combined Reporting

55 published works

  1. SALT Shaker

    Take Control! Massachusetts Clarifies Common Ownership Requirement for Combined Reporting

    By Eversheds Sutherland SALT

    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…

  2. SALT Shaker

    New York: Disallowance of Mandatory Combined Reporting Position Sustained

    By Eversheds Sutherland SALT

    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…

  3. Inside SALT

    New York Issues First New Combined Reporting Law Determination—and It’s Not Pretty

    By Arthur R. Rosen

    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…

  4. SALT Shaker

    D.C. Proposes to Extend Deadline for Combined Reports

    By Eversheds Sutherland SALT

    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…

  5. SALT Shaker

    A Pupu Platter of a Case: Packaging and Filtration Businesses Held Unitary

    By Eversheds Sutherland SALT

    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…

  6. SALT Shaker

    Another Oregon Tax Court Decision Regarding Insurance Companies and Combined Reporting

    By Eversheds Sutherland SALT

    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…

  7. SALT Shaker

    Indiana Combination Is Last Resort

    By Eversheds Sutherland SALT

    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…

  8. SALT Shaker

    New York Attempts to Take Taxpayer Out Behind the (Kell)Woodshed

    By Eversheds Sutherland SALT

    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…

  9. SALT Shaker

    Who Lost the Remote?: Virginia Disallowed Losses and Combined Reporting

    By Eversheds Sutherland SALT

    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…

  10. SALT Shaker

    De-Combining Hoosiers

    By Eversheds Sutherland SALT

    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…