In recent years, an increasing number of states have considered or adopted unitary/combined reporting tax regimes, including the District of Columbia, West Virginia, Wisconsin, Michigan, and Massachusetts – as this is a way for state Departments of Revenue to raise revenue and close perceived “tax loopholes.” Combined reporting brings unique and challenging issues, including unitary/ownership rules, apportionment rules, and tax attribute utilization rules.
Grant Thornton is a thought leader in the arena of combined reporting and has been published in the various articles listed below:
In Whirlpool Properties, Inc. v. Director, Division of Taxation, the New Jersey Supreme Court affirmed, with modification, a 2010 decision of the New Jersey Superior Court, Appellate Division regarding the facial constitutionality of New Jersey’s “throwout rule” under the Due Process Clause and the Commerce Clause.
This website supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the subject of this document we encourage you to contact us or an independent tax advisor to discuss the potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this document may be considered to contain written tax advice, any written advice contained in, forwarded with, or attached to this document is not intended by Grant Thornton to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.