News & Analysis as of

Gore Decided: Unitary Nexus Rejected; Economic Substance Test Clarified

Today, the Maryland Court of Appeals issued its highly anticipated decision in Gore Enterprise Holdings, Inc. v. Comptroller of the Treasury; Future Value, Inc. v. Comptroller of the Treasury. The court held that under the...more

U.S. Supreme Court Update - January 2014

Court Begins 2013-2014 Term - Upon starting its 2013-2014 term during the government's recent partial shut-down, the U.S. Supreme Court opened with a grant of certiorari in a case with state and local tax implications,...more

New Jersey Tax Court Issues Important Order on the State’s Throw Out Rule

The Tax Court of New Jersey recently issued an important order that may have eviscerated the impact of the Throw Out Rule on intangibles holding companies. On its face the order does not appear to address the application of...more

‘Inherited’ Nexus And Other Extreme Nexus Theories

Nexus — whether a corporation has a sufficient connection such that it may be taxed by a state — is one of the most important issues in state tax. Various legal theories have been asserted (and are being asserted) to justify...more

State & Local Tax Alert: Recent Developments in the State Taxation of Pass-Through Entities

In This Issue: - Nonresident Owner Nexus - Apportionment of Multistate Income - Entity-Level Income Tax Withholding - Composite Returns - Entity-Level Taxes - Issues Unique to S...more

No Oregon Income Tax Nexus For Company Owning Intangibles Used In State

A federal bankruptcy court judge has held that Washington Mutual, Inc. (WMI), a parent holding company that owned bank subsidiaries conducting business in Oregon, did not have nexus in Oregon by virtue of its ownership of the...more

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