On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The...more
6/17/2016
/ Administrative Law Judge (ALJ) ,
B&O Tax ,
Commerce Clause ,
Corporate Taxes ,
Department of Revenue ,
Determination Letter ,
Dormant Commerce Clause ,
Double Taxation ,
Due Process ,
Economic Presence Nexus ,
Foreign Commerce Clause ,
Germany ,
Lack of Authority ,
Non-Discrimination Rules ,
Pharmaceutical Industry ,
Royalties ,
Tax Treaty
A New York State Division of Tax Appeals administrative law judge (ALJ) recently determined that a banking corporation was not required to hypothetically use a net operating loss (NOL) deduction to decrease its entire net...more
A New York State Division of Tax Appeals administrative law judge (ALJ) recently ruled in Matter of TD Holdings II, Inc., DTA No. 825329 (N.Y. Div. Tax App. Jan. 22, 2015), that a banking corporation is not required to...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