Apportionment Corporate Taxes

News & Analysis as of

Allocation, Due Diligence, and More Record Keeping! New Draft Regulations on New York State’s Corporate Income Tax Allocation

2014 brought significant corporate income tax reform to New York State. This year, 2015, followed suit and brought many of those same corporate income tax reforms to New York City. To quote Donald Trump, these reforms are...more

Single Sales Factor Apportionment May Be Coming to North Carolina

In the last two years, the General Assembly has enacted major changes to North Carolina’s corporate income tax law, including significant rate reductions, elimination of numerous incentive credits and replacement of North...more

Wynne’s First Casualty: First Marblehead Corp. v. Commissioner

Today, the U.S. Supreme Court vacated the decision of the Massachusetts Supreme Judicial Court (SJC) in First Marblehead Corp. v. Commissioner of Revenue (First Marblehead) and remanded the case back to the court for...more

California Updates Conformity to Internal Revenue Code, Provides Large Corporate Understatement Penalty Relief

Governor Jerry Brown signed Assembly Bill 154 on September 30, 2015, updating California’s general conformity to the Internal Revenue Code and providing three new exceptions to the imposition of the Large Corporate...more

Business Incentive Changes in Recent North Carolina Legislation

The North Carolina General Assembly passed two significant pieces of legislation affecting corporate activity, expansion and new investment in North Carolina. First, the General Assembly passed the state budget...more

Court of Appeals Hears Michigan’s Compact Election Cases

The long saga of Michigan's Multistate Tax Compact election continued on Wednesday with oral argument before the Michigan Court of Appeals. A packed courtroom witnessed a 1.5 hour proceeding before an active three-judge...more

Global Tax News - July 2015

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

North Carolina Moves Towards Single Sales Factor and Market Sourcing

An earlier Tax Alert discussed the possibility that North Carolina would adopt the single sales factor method of apportioning the business income of multi-state corporations. During the current legislative session, single...more

Inside the New York Budget Bill: 2015 – 2016 Budget Legislation

In This Issue: - Technical Correction .. Economic Nexus .. Tax Base and Income Classifications .. Tax Rates and Qualified New York Manufacturers .. Apportionment .. Combined Reporting .. Net...more

It’s Your Burden: South Carolina Supreme Court Rejects Department of Revenue’s Application of Alternative Apportionment

The South Carolina Supreme Court issued its decision in CarMax Auto Superstores West Coast, Inc. v. S.C. Dep’t of Revenue, Opinion No. 27474 (S.C. Dec. 23, 2014), holding that the South Carolina Department of Revenue (the...more

Focus on Pennsylvania Corporate Taxes

With the November 4th election of Democrat Tom Wolf as Pennsylvania’s next Governor, Pennsylvania corporate taxpayers face an interesting budget season in 2015. During the campaign, Wolf advocated for a severance or...more

Southeast State & Local Tax: Important Developments - September/October 2014

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA - INDIVIDUAL INCOME TAX...more

Massachusetts Tax Developments: A Reed Smith Quarterly Update (3rd Quarter 2014)

Welcome to the latest Reed Smith Massachusetts State Tax Quarterly Update. In this update, we’ll look back to the developments from the first half of 2014, and look ahead to market-based sourcing and other issues on the...more

Can Taxpayers Find an Advantage in Vodafone Nowhere Income Argument?

It is difficult, but not impossible (and quite satisfactory), to find a silver lining for taxpayers in the alternative apportionment opinion Vodafone Americas Holdings Inc. v. Roberts, M2013-00947-COA-R3CV, 2014 WL 2895900...more

Cross-Border Interest Expense Apportionment Regulations Finalized

The IRS issued cross-border interest apportionment final regulations. These adopt the approach from the 2012 temporary regulations, requiring a 10% corporate partner to apportion its interest expense by reference to the...more

New York Budget Legislation

On March 31, 2014, New York State Governor Andrew Cuomo signed into law the 2014-2015 New York State Budget (Budget), which results in the most significant overhaul of New York’s franchise tax in decades. The Budget brings...more

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