Two states recently unveiled transfer pricing enforcement tactics to, in their view, combat improper intercompany profit shifting.
On Friday, July 24, 2020, the Commonwealth Court of Pennsylvania issued its decision and order on the Pennsylvania Department of Revenue’s motion to intervene in the highly-anticipated case of Synthes USA HQ, Inc. v. Commonwealth of Pennsylvania, No. 108 F.R. 2016. The Synthes case is noteworthy not only because the Commonwealth Court addresses, for the first time, the Department of Revenue’s hotly debated interpretation of the state’s former “costs of performance” statute, but also because…
Given the positive feedback from our weekly webinar series, the Baker McKenzie SALT Team is launching a monthly webinar that will cover coast-to-coast state and local tax developments. The purpose of this webinar is to keep you informed of updates and trends that may impact your business. Our first session will take place on Wednesday, July 8, 2020 from 1:00 – 2:00 pm ET. Presenters will include Lindsay LaCava, Stephen Long, Mike Shaikh, and Roman…
The Idaho Supreme Court recently affirmed a District Court’s judgment that the gain from the sale of a 78.54% membership interest in a limited liability company did not constitute “business income” under Idaho Code section 63-3027. In Noell Indus. Inc. v. Idaho State Tax Comm’n, Docket No. 46941 (Idaho 2020), the court determined that “this type of gain does not meet the definition of ‘business income’ under either the transactional test or functional test (including the unitary business test),” and was therefore not apportionable income.