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Combined reporting for corporate tax

USA
15 Dec 2014

The latest machination of New York State combined reporting is set to take effect in 2015. Taxand USA highlights the relevant changes in the State’s latest combination provisions.

For tax years 2015 and after combined reporting is required when corporations meeting a greater than 50% common ownership test are engaged in a unitary business. The new law eliminates substantial intercorporate transactions and distortion as considerations. Also, taxpayers may elect to include all commonly owned corporations in the combined report, regardless of whether they are conducting a unitary business.

Under the new combined reporting regime, businesses could avoid potential controversies by electing to treat their commonly owned group as their combined group, regardless of whether they constitute a unitary business. However, the election is applied on an all-or-nothing basis to the non-unitary companies. 

Discover more: New York State combination: I’ll have combo number...


Your Taxand contact for further queries is: 
Benjamin Diaz
T.+1 305 704 6650
E. bdiaz@alvarezandmarsal.com

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Also published in Thomson Reuters' Taxnet Pro

Taxand's Take

New York State combination continues to morph, but the Department’s emphasis and dedication of resources towards combination issues appear likely to remain constant. Therefore, companies must continue to maintain sufficient facts to support their positions and detailed files to substantiate potential audits and litigation.

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