Indiana: Subsidiary sales treated as business income and interest expense disallowed

September 2013

Overview

A Letter of Findings held that income from taxpayer’s subsidiary sale was business income. The decision found that the US Supreme Court Meadwestvaco decision did not require that a unitary relationship exist. The decision disallowed related party interest expenses because they resulted in a failure to ‘fairly reflect’ Indiana income. The decision could be read to apply Indiana’s addback (for intangible expenses and related intangible interest expenses) to related party loan interest expense

Contact us

Peter Michalowski
National SALT Practice Leader
Tel: +1 (646) 471 5259
Email

Follow us