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Connecticut

Explanation of 2003 Law disallowing related-party interest deductions
 

Delaware
 
Massachusetts Add Back of Interest or Intangible Expense Corporate Exercise
Select Supreme Judicial Court and search for royalties to find court cases involving the deductibility of royalties paid to related trademark holding companies.  Especially: The Sherwin-Williams Company v. Commissioner of Revenue, Syms Corp. v. Commissioner of Revenue, and General Mills v Commissioner of Revenue
 
Maryland

Release on Settlement offer for taxes on payments to Delaware Holding Companies

Maryland Court of Appeals decision on Delaware holding companies (note, U.S. Supreme Court declined to review this decision 12/13/03)

New Jersey

 

Search for related party to find The Special Adoption and concurrent proposal pursuant to the Business Tax Reform Act

State taxation of foreign intangibles holding company
 

New York Sherwin-Williams Company v. Commissioner
Administrative Law Judge's decision that Hallmark affiliates' had arm's length pricing with parent.

Delaware Holding Company Case Involving Lowe's Home Centers, Inc.

H.W. Wilson Company Foreign Sales Corp. not required to be in state tax return because transactions were arm's length.


 


 

 

 


 

 

 

 

 

 

 

 

 
   
 
 
 
 
 
 
 
 
 
 

 

 



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