Even though New York amended its combination statute for years beginning in 2007, we are just now beginning to see litigation related to those amendments. At the end of June 2013, an administrative law judge in New York’s Division of Tax Appeals issued the first determination analyzing the new law. The analysis in Matter of Knowledge Learning Corporation was notably quite restrictive, resulting in a taxpayer loss.
New York Issues First New Combined Reporting Law Determination—and It’s Not Pretty
By Arthur R. Rosen on July 8, 2013
Posted In Income Tax, New York
Arthur R. RosenArthur R. Rosen focuses his practice on tax planning and litigation relating to state and local tax matters for corporations, partnerships and individuals. Formerly the deputy counsel of the New York State Department of Taxation and Finance, as well as counsel to the governor's Temporary Sales Tax Commission and tax counsel to the New York State Senate Tax Committee, Arthur has also held executive tax management positions at Xerox Corporation and AT&T. He has worked in accounting and law firms in New York City. Read Arthur Rosen's full bio.
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