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Royalties State Taxes

Blank Rome LLP

NY Appellate Court Finds That IBM Cannot Deduct Foreign Royalty Payments

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A New York intermediate appellate court upheld a New York State Tax Appeals Tribunal determination finding that International Business Machines Corp. and its combined affiliates (together, “IBM”) improperly deducted royalty...more

Lewitt Hackman

Franchisor 101: Franchisor Fails to Escape State’s Changed Tax Interpretation

Lewitt Hackman on

A state appellate court (“Court”) in New Mexico upheld a decision by the state’s Taxation and Revenue Department (“Department”) that royalties paid to out-of-state franchisors are subject to the state’s gross receipts tax...more

Morrison & Foerster LLP

Virginia Supreme Court Rules on Subject-to-Tax Safe Harbor to the Royalty Addback

In a 4-3 decision, the Virginia Supreme Court held that the subject-to-tax safe harbor to the royalty addback was ambiguous and applies only to the extent that the royalties are actually taxed by another state. In addition,...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 8

ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

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