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House Judiciary Committee Holds Hearing on State Taxation and the Role of Congress in Developing Apportionment Standards

LEGAL ALERT May 7, 2010 On May 6, the House Judiciary Subcommittee on Commercial and Administrative Law (CAL), chaired by Representative Steven Cohen (D-TN), held a hearing on state income taxation to explore what role, if any, Congress should play in developing apportionment uniformity...

Florida DOR on Hedging: Mixed Bag or Safe Bet to Plan Future Transactions?

A Florida taxpayer was engaged in three types of hedging activity: (1) hedges on materials related to its inputs; (2) hedges related to the commodity it sells; and (3) hedges unrelated to items it purchases or sells. In deciding whether the hedging revenue was properly included in the taxpayer's...

States Target Inter-Company Cash Management Structure

A common aspect of consolidated groups of companies is a centralized cash management function. While such a structure is a common item in corporate America, states are increasingly challenging any perceived tax benefits of such structures. Two states, Indiana and North Carolina, have taken recent actions...

States Target Inter-Company Cash Management Structure

A common aspect of consolidated groups of companies is a centralized cash management function. While such a structure is a common item in corporate America, states are increasingly challenging any perceived tax benefits of such structures. Two states, Indiana and North Carolina, have taken recent actions...

Vexing Apportionment Challenges Stymie Flummoxed Tax Departments

The murky waters of state taxation, now characterized by single-sales-factor apportionment and economic nexus trends, continue to plague corner office decision-makers and the practitioners who counsel them. [See "Experts: Economic Nexus and Single-Sales-Factor Apportionment May Lead to Discrimination...