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Introduction On June 12, 2014, the European Court of Justice ("ECJ") delivered its decision in SCA Group Holding BV and others. (1) The ECJ held that the Dutch fiscal unity [...]

No Code section is an island. While the transfer pricing rules promulgated under Code Sec. 482 are sometimes viewed as a discrete area, designed to assure that related parties are [...]

Byline: Rochester Business Journal Staff Federal tax reforms passed in late 2017 drastically overhauled the national income tax system, and businesses and accountants are preparing to file taxes under the [...]

October 15, 2009 On October 15, 2009, Tax Executives Institute filed the following comments with the Wisconsin Department of Revenue relating to proposed regulations implementing the State's recently enacted mandatory [...]

Since being enacted in July 2007, the Michigan Business Tax (MBT) has undergone constant legislative changes and administrative clarifications in the form of revenue administrative bulletins (RABs) and frequently asked [...]

A recent Alabama ruling holds that the taxpayer overcame the administrative presumption of unity, even though the affiliated entities were in the same line of business and shared a common [...]

On April 15, 2008, the U.S. Supreme Court handed down its ruling in MeadWestvaco Corp. v. Illinois Dep't of Revenue. (1) The issue in this case is whether the State [...]

Introduction It has been observed that the tax law deals essentially with only two major issues, namely, character and timing. (2) While there are many important character issues to deal [...]

The U.S. economic landscape consists mostly of small businesses. In 1997, of the 5,541,900 businesses in the United States, 98.3% had fewer than 100 employees. To keep abreast of the [...]

The Streamlined Sales Tax SSTP (SSTP) is an effort created by state governments, with input from local governments and the private sector, to simplify and modernize sales and use tax [...]

Tax planners for multinational businesses need to be aware of the varied state income tax systems that these businesses may be subject to, and planners must ensure that tax considerations are integrated into corporate policies. The water's edge election available in some states can turn worldwide combined reporting from a tax burden to a planning opportunity if the planner is aware of the limitations of the election. States vary as to their tax treatment of foreign branch operations and whether dividends are included in the tax base used for apportionment.

Byline: AMY LANE Business is looking for change. And it's willing to lend expertise to help Gov.-elect Rick Snyder make it happen. Whether it's improvements in the state regulatory process, [...]

Byline: AMY LANE Pledging to cut business taxes is the easy part. The harder part -- and controversy -- will come when Virg Bernero or Rick Snyder try to turn [...]

Byline: Amy Lane Businesses that have delinquent tax liabilities might want to put May 15 on their calendars. That's when the state will begin a 45-day tax amnesty period that [...]

Taxpayers involved in cash businesses are frequently under the incorrect impression that they are audit-proof and free from risk of criminal liability when the income and deductions reflected on their [...]

It wasn't mentioned in the bevy of tax-related press releases flying around the Capitol last week, but a repeal of the Michigan Business Tax surcharge remains on some lists as [...]

Wednesday's meeting is expected to address two particularly controversial bits of business, including a discussion of the bill's treatment of the Community Reinvestment Act and challenges to its language on [...]

This summer Massachusetts enacted a law aimed at simplifying the corporate tax structure and raising revenue while cutting corporate tax rates (An Act Relative to Tax Fairness and Business Competitiveness, [...]

In a recent letter decision, the California State Board of Equalization (SBE) ruled that a taxpayer's combined report should include a wholly owned unitary insurance subsidiary (SBE Letter Decision No. [...]

If a unitary relationship exists between a group of legal entities, certain states would require the group to file a combined income tax return. Generally, a state presumes a unitary [...]

California's controversial unitary business tax has been amended. The previous law required all multistate and multinational corporations doing business in California to file combined corporate returns. The new law introduces the so-called 'water's edge' concept, which allows certain foreign corporations to be excluded from the combined return. Procedures for electing a worldwide or water's edge basis are discussed. The rules for election fees, the treatment of foreign dividend income, interest-offset, and domestic disclosure are discussed.