News & Analysis as of

Combined Reporting

McDermott Will & Emery

Colorado Changes Rules for Determining Members of Combined Filing Group

McDermott Will & Emery on

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

McDermott Will & Emery

Be Careful What You Wish For: Minnesota May Be on the Precipice of Enacting Worldwide Combined Reporting at the Worst Possible...

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

Knobbe Martens

Expert Testimony Must Be Tethered to Supporting Evidence

Knobbe Martens on

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

McDermott Will & Emery

California FTB to Discuss Apportionment of Combined Group Income

McDermott Will & Emery on

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

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 2

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

Morrison & Foerster LLP

New York State Tax Department Releases Draft Combined Reporting Regulations Under Corporate Tax Reform

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

Morrison & Foerster LLP

Out-of-State Subsidiary Holding Company Cannot Be Forcibly Included in a Colorado Combined Return

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

McDermott Will & Emery

Connecticut Limits New Tax Haven Law

McDermott Will & Emery on

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

Bradley Arant Boult Cummings LLP

Third Time’s a Charm: Governor Bentley and Legislature Reach Budget/Tax Compromise

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

McDermott Will & Emery

California’s Harley-Davidson Decision Rides over Nexus Lines

McDermott Will & Emery on

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

McDermott Will & Emery

District of Columbia’s Transfer Pricing Enforcement Program and Combined Reporting Regime: Taking Two Bites of the Same Apple

McDermott Will & Emery on

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

McDermott Will & Emery

Yes, Distortion is Enough: New York Tax Appeals Tribunal Clarifies Combined Reporting Requirements

McDermott Will & Emery on

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

McDermott Will & Emery

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 2013, an administrative law judge in New York’s...more

Eversheds Sutherland (US) LLP

Legal Alert: D.C. Proposes to Extend Deadline for Combined Reports

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

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 4, Issue 2 - February 2013

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

15 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide