Indiana- Subsidiaries excluded from consolidated return due to absence of Indiana source income and because of an unfair reflection of income


The Indiana Department of Revenue excluded an entity from a consolidated group because it did not have Indiana source income. Neither excluded dividend income nor reimbursements to a "common paymaster" resulted in Indiana source income. The Department excluded another entity from a consolidated group because the subsidiary's intercompany interest expense resulted in an unfair reflection of income. [Indiana Supplemental Letter of Findings, 02-20110565 (8/29/12)]

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