Intangible Holding Company

News & Analysis as of

Division Avoids Another Throwout Defeat, But Puts Economic Nexus at Risk

Earlier this week, the New Jersey Tax Court released a letter opinion in Whirlpool Properties Inc. v. Director, its latest decision involving throwout. The Division of Taxation had argued that there were unresolved factual...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

Tennessee Department of Revenue Issues Last Call for Intangible Holding Company Voluntary Disclosure

The Tennessee Department of Revenue issued Notice 13-06 in June notifying taxpayers that its acceptance of voluntary disclosure of intangible expense deductions at a preferred settlement rate will be ending later this year....more

W.L. Gore’s Impact on Pending Maryland Cases and Audits

In a case decided late last month, Comptroller of the Treasury v. Gore Enterprise Holdings, Inc. and Future Value, Inc., Nos. 1696 and 1697 (January 24, 2013), the Maryland Court of Special Appeals held that patent royalties...more

Inside Maryland State Taxes: And the Saga Continues…Maryland Tax Court Hears New Intangible Holding Company Case

Last week, the Maryland Tax Court heard arguments in ConAgra Brands, Inc. v. Comptroller of the Treasury, No. 09-IN-OO-0150. ConAgra Brands is the most recent case in which the Comptroller has asserted nexus over an...more

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