North Carolina Department of Revenue proposes combination rules

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The North Carolina Department of Revenue on October 22, 2012, issued proposed regulations regarding the Secretary of Revenue's authority to adjust net income or to require combined returns when intercompany transactions lack economic substance or are not at fair market value. For the first time, the Department provided limited procedural guidance on the filing of a combined franchise tax return. The proposed regulations are in response to H.B. 619, enacted 6/30/11, conferring combination authority upon the Secretary and S.B. 824, enacted 6/20/12, requiring the Department to adopt rules before the Secretary may exercise such authority.



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