Colorado Governor Jared Polis has signed legislation that would replace Colorado’s unique “3 of 6” rule for determining the members of a unitary group for combined reporting purposes and instead adopt what Legislative Council...more
It has been widely reported that the Minnesota Legislature has advanced an omnibus tax bill that would require the inclusion of the “entire worldwide income” of combined corporate income tax filers engaging in a unitary...more
Before Reyna, Hughes, and Stoll. Appeal from the Patent Trial and Appeal Board. TQ DELTA, LLC v. CISCO SYSTEMS, INC. Summary: Findings of fact at the PTAB must be supported by substantial evidence, and conclusory expert...more
The California Franchise Tax Board (FTB) will hold a second Interested Parties Meeting at their office in Rancho Cordova on April 20, 2016, dealing with the apportionment of income for combined reporting groups with both...more
State Tax Department Releases New Draft Article 9-A Combined Reporting Regulations - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax...more
The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise tax regulations to address significant changes to combined reporting under New York State corporate...more
A Denver District Court judge has held that the Colorado Department of Revenue cannot forcibly combine a corporation’s subsidiary, a holding company that derived its income solely from investments in foreign entities, in...more
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 Conn. Gen. Stat. P.A. 15-5, § 144 (2015),...more
Summary - Governor Robert Bentley called a second special session of the Alabama Legislature on Tuesday, September 9 at 5 p.m. to address the FY 2016 General Fund budget and associated revenue measures. After meeting for...more
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 the validity of an election within...more
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 implemented combined reporting tax regime is...more
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 that has been lingering in the...more
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 2013, an administrative law judge in New York’s...more
In the latest step to fine-tune the implementation of the District of Columbia’s mandatory unitary combined reporting statute, the Office of Tax and Revenue (OTR) has issued a taxpayer-friendly proposed regulation that would...more
In This Issue: Divided Appellate Division Affirms Tribunal’s Gaied “Permanent Place of Abode” Decision; Combined Reporting Permitted by ALJ Despite Absence of Substantial Intercorporate Transactions; Commissions Paid...more