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
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