South Carolina Supreme Court Media General Decision Alters the Landscape for Combined Reporting by Taxpayers

On June 14, 2010, the South Carolina Supreme Court reversed a long-standing policy in the state and ruled that a communications company and its subsidiaries could file on a combined basis. In Media General Communications v. South Carolina Dept. of Rev., the court held that the state's relief statute, incorporating UDITPA § 18, provided the department the necessary authority to permit combined reporting. In this interview, BNA speaks with Geoffrey J. Christian, member of Dow Lohnes Price Tax Consulting Group LLC, in Greenville, S.C., about the decision. Dow Lohnes Price served as a consultant to the taxpayer and helped to develop its tax strategy.

Read Geoffrey J. Christian's interview by Dolores W. Gregory here.


Reproduced with permission from Tax Management Multistate Tax Report, Vol. 17 No. 8 (August 27, 2010). Copyright 2010 The Bureau of National Affairs, Inc. (800-372-1033) www.bna.com

Court Rules on Entity Apportionment in Tax Case [WebCPA]

A case decided on June 14, 2010, by the South Carolina Supreme Court may have nationwide implications on tax reporting.


Geoff Christian discusses the decision.

Full story here at Accounting Today for the WebCPA.

South Carolina Supreme Court Decision Reached in Alternative Apportionment Case

This announcement provides a description of the recent ruling handed down by the South Carolina Supreme Court in Media General, Inc. et al. v. South Carolina Department of Revenue. Dow Lohnes Price developed an alternative apportionment position to fairly reflect the apportionment of taxpayer’s income to South Carolina and provided legal, computational, and analytical expertise in this case beginning with the audit phase through litigation.

See complete announcement here.

How to Fight Back Against State Tax Audit Assessments: Developing an Advantageous Relationship with Your Auditor

To many taxpayers, the average audit is a nuisance—and the temptation to simply settle and move on is very strong. In an earlier article, Geoffrey J. Christian, of Dow Lohnes Price Tax Consulting LLC, laid out a case for the long-term benefits that arise when a taxpayer pushes back against audit assessments. In this article, Marshal Kline of Dow Lohnes Price, discusses one of the most effective tools available to any tax professional—creating a good rapport with the auditor.


In our present environment, where state tax audits in all areas of taxation are on the rise, many tax professionals find themselves spending more and more time being reactive than proactive. Fewer are the days tax professionals go to work and actually find themselves devoting their time to the things they intended. Instead, they are being pulled in a variety of directions, scheduling field audits, responding to information document requests (IDRs), reviewing notices of deficiency along with the related workpapers and analyses, drafting protests in response to same, and, when there is time, preparing the tax returns that begin the whole process anew.


To continue reading entire article, click here .


Reprinted with permission from BNA Tax Management Weekly State Tax Report.  Authored by Marshal Kline, Dow Lohnes Price Tax Consulting Group, and published by BNA Tax Management Weekly State Tax Report on May 28, 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.

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.