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Chaos: The District of Columbia Enacts Combined Reporting and "Fixes" Expense Disallowance Provisions by Stephen P. Kranz
Sutherland Asbill & Brennan LLP - Washington Office
Michele Borens
Sutherland Asbill & Brennan LLP - Washington Office
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September 17, 2009
Previously published on September 15, 2009
In an unusual twist, the District of Columbia (the District) passed emergency legislation that adopts mandatory combined reporting and corrects existing statutory construction problems with the District's related party expense disallowance provisions. Combined reporting was not seriously considered until it appeared as a proposal in the City's budget legislation seeking to address the City's budget deficit - which is estimated to be in the hundreds of millions. While combined reporting has been adopted by the District, there are no details included in the legislation as to how combined reporting will be applied. Sutherland will be working with the District to address these ambiguities.
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