• Massachusetts Commissioner of Revenue Narrows the Deductibility of Intercompany Intangible Expenses
  • November 13, 2003
  • Law Firm: Dechert LLP - Office
  • The Massachusetts Commissioner of Revenue has narrowed the deductibility of intercompany intangible expenses. We previously reported that a Massachusetts corporate taxpayer could, despite recent legislation, continue to deduct intangible expenses paid to an affiliate if: (1) the affiliate files an income tax return in any state; and (2) the Massachusetts taxpayer's Massachusetts apportionment percentage is 31.57% or less. This position was based on Technical Information Release 03-19 and tax-return schedules ABI and ABIE issued by the Commissioner.