Register to receive Taxand’s latest opinion on topical tax news
News › Weekly Alert Article
Combined reporting for corporate tax
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.
Quality tax advice, globally
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.