News & Analysis as of

Unitary Business

Michigan Treasury Issues Revised Interpretation of Unitary Business Groups Following LaBelle Decision

by Varnum LLP on

On February 28, 2017, the Michigan Department of Treasury issued guidance in response to the Supreme Court's denial of Treasury's application to appeal LaBelle Management, Inc v Michigan Department of Treasury, 315 Mich App...more

Check Your Michigan Unitary Group Filings - LaBelle Is Final

On February 28, 2017, the Michigan Department of Treasury (the Department) issued a Notice to Taxpayers (the Notice) explaining its approach in administering the now final Michigan Court of Appeals decision in LaBelle...more

Decision on Unitary Group Stands after Michigan Supreme Court Chooses Not to Review

by Varnum LLP on

On January 24, 2017, the Michigan Supreme Court denied the application filed by the Michigan Department of Treasury (the "Department") for leave to appeal the Court of Appeals' published decision in LaBelle Management v...more

NJ Senators Hold Press Conference on Combined Reporting

by Reed Smith on

New Jersey Senators Lesniak (D), Greenstein (D), and Sarlo (D) held a press conference today concerning combined-reporting legislation that they are sponsoring....more

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

by Morrison & Foerster LLP on

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 Steep Slope — Vermont Supreme Court Finds AIG Not Unitary With a Ski Resort Based On a Clear and Cogent Evidence Burden of Proof

by McDermott Will & Emery on

In the first Vermont Supreme Court decision addressing combined unitary reporting since Vermont’s combined reporting regime became effective in 2006, the court affirmed a lower court’s decision that AIG, the multinational...more

California Tax Developments - A Reed Smith Quarterly Update (2nd Quarter 2015)

by Reed Smith on

Case Updates - BREAKING NEWS: Gillette Oral Arguments Scheduled - The California Supreme Court has scheduled oral arguments in the Gillette Multistate Tax Compact case. This comes three years after the California...more

MoFo New York Tax Insights - Volume 6, Issue 6 - June 2015

by Morrison & Foerster LLP on

In This Issue: - Tribunal Reverses ALJ and Permits Combination Based on Unitary Business and Distortion - “Flat Sum Settlement” with IRS Held Not to Constitute Reportable Federal Change - Tribunal Holds NYS...more

NYS Tax Appeals Tribunal Provides Guidance Respecting Unitary Business Determinations

by McDermott Will & Emery on

The New York State Tax Appeals Tribunal has just provided timely guidance respecting the unitary business rule in New York State. In SunGard Capital Corp. and Subsidiaries (DTA Nos. 823631, 823632, 823680, 824167, and...more

California Tax Developments - A Reed Smith Quarterly Update (1st Quarter 2014)

by Reed Smith on

Case Updates - Superior Court deems Comcast and QVC are not unitary; determines early termination fee is business income. On March 6, 2014, a Los Angeles Superior Court issued its final decision in Comcon Production...more

Legal Alert: Court Holds Comcast Did Not Establish Unitary Relationship with QVC

Yesterday the Los Angeles Superior Court held that Comcast did not establish a unitary relationship with its 57% owned subsidiary, QVC. The court found for Comcast and held that the evidence presented at trial demonstrated...more

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

by Reed Smith on

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

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