In Department of Taxation v. FJ Management, Inc.the Virginia Court of Appeals recently concluded that the apportionment factors of a partnership in which a taxpayer held a minority interest could not flow up to the partner because there was no unitary relationship between the partner and the partnership. As state scrutiny over apportionment

Bloomberg Tax

Multinational corporations have long battled the IRS and other nations’ taxing authorities over their transfer pricing arrangements.

But transfer pricing examinations and disputes at the state level can be even more challenging due to a lack of consistency and transparency, particularly in states that require entities conducting a unitary business to file separate

Reprinted from Tax Notes State, April 22, 2024

It’s hard to believe it’s been over five years since the Maryland Court of Special Appeals held in Staples Inc. that an out-of-state parent could be subject to tax in the state by virtue of royalty payments made by in-state related entities despite all intercompany transactions

Last week, South Carolina Governor McMaster signed into law Act No. 113 in a much needed reproach to the Department of Revenue’s aggressive attempts to undermine the state’s separate reporting regime for apportioning corporate income. While the law creates a new paradigm for how and in what manner the state or taxpayer may obtain alternative

The very first “courtroom” I ever entered as a newly minted lawyer was at the Chicago Administration Hearings Department at 400 W. Superior Street. That case, if I recall correctly, was about the city’s Real Property Transfer Tax and what portion of the sales price in a particular transaction was attributable to the transfer of