The Virginia Supreme Court granted the Company’s petition for rehearing and confirmed that the Department of Revenue’s interpretations that are not contained in regulations are entitled to no weight. ...more
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
On August 31, 2017, in a 4-3 split decision, the Virginia Supreme Court (Court) affirmed a circuit court’s ruling that in order for income to qualify for the “subject-to-tax” exception to its addback statute, the income must...more
On August 31, 2017, the Virginia Supreme Court issued its opinion holding that only the portion of royalties that are actually taxed by another state falls within its “subject to tax” exception to Virginia’s addback statute...more