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A Pinch of SALT: Using the Force to Combine in Separate Return States

Most separate reporting states give the department of revenue discretionary authority to require affiliated companies to file a combined return under certain conditions. This authority can be a valuable whe

September 7, 2011

Most separate reporting states give the department of revenue discretionary authority to require affiliated companies to file a combined return under certain conditions. This authority can be a valuable when applied fairly and appropriately but can cause significant problems when abused. In this A Pinch of SALT, Sutherland SALT attorneys Jonathan Feldman and Madison Barnett use the recent "trials" and tribulations in North Carolina as a case study to illustrate the manner in which a state's authority should be exercised.

 

Read "Using the Force to Combine in Separate Return States," reprinted with permission from the September 5, 2011 issue of State Tax Notes.

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