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

September 2012

Overview

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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