Friday, March 26, 2010

SC Supreme Court Hears Oral Arguments on Combined Filing Case

On March 16, 2010, the South Carolina Supreme Court heard oral arguments in the appeal of Media General Communications, Inc. & Media General Broadcasting of South Carolina Holdings, Inc. v. S.C. Dept. of Rev. & Media General, Inc. v. S.C. Dept. of Rev., Admin. Law Ct. Docket Nos. 07-ALJ-17-0089-CC, 07-ALJ-17-0090-CC (May 4, 2009).

View announcement here.

Monday, March 15, 2010

Are Your State Audits Ridiculous? It's Time to Push Back!

It's important to stand firm against aggressive state auditors who attack your tax reporting positions. This article examines how you can successfully navigate through an arbitrary or unreasonable assessment and use the "push back" approach to gain favorable results in the audit battle.

Please click here to view the full article.  Reprinted with permission from BNA Tax Management Weekly State Tax Report.

Authored by Geoffrey J. Christian, Dow Lohnes Price Tax Consulting Group and published by BNA Tax Management Weekly State Tax Report on January 22, 2010.

Thursday, March 4, 2010

SALT To Taste: How Important is Consistency Among "Uniform" States that are not so Uniform?

Many states have adopted and incorporated uniform acts into their tax statutes.  Recently, an Oregon case considered whether consistent reporting positions among such states should be mandatory regardless of each state's distinct interpretation and application of their own tax statutes.  This article looks at the Oregon court's conclusion that a taxpayer's facts can result in disparate treatment among states and that the treatment of any item is controlled by a state's laws.  As a result, great diligence should be taken to analyze the laws of each state when establishing tax reporting positions.

Read this SALT To Taste newsletter here.

SALT To Taste: To What Extent Should Taxpayers Rely on State Statutes and Regulations in Flowing Through Apportionment Factors of a Partnership to Corporate Partner?

Properly acknowledging critical U.S. Constitutional principles when apportioning the income of a partnership is key when preparing state corporate income tax returns and guarding against erroneous state assertions involving the state's interpretation of statutes and regulations. In this article, see an example of how a state could misapply these Constitutional principles.

Read this SALT To Taste newsletter here.