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New York State Administrative Law Judge Rejects Forced Combination and State's Attack on Taxpayer's Transfer Pricing |
January 29, 2007
Previously published by State Tax Notes on March 6, 2006
A New York State administrative law judge ("ALJ") has issued a determination rejecting an attempt by the New York State Department of Taxation and Finance to forcibly combine an out-of-state manufacturing corporation with its in-state affiliated distribution company for New York State corporation franchise tax purposes, finding that the taxpayer successfully proved that its intercompany pricing was consistent with Internal Revenue Code ยง 482 principles.
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The views expressed in this article are solely the views of the author and not Martindale-Hubbell. This article is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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