Oregon – Unitary reporting group includes 'tax haven’ entities

On August 1, 2013, Oregon Governor John Kitzhaber signed H.B. 2460, which requires the income and apportionment factors of unitary corporations incorporated in certain ‘tax haven’ countries to be included in a taxpayer’s Oregon combined unitary tax return. The bill is effective for tax years beginning on or after January 1, 2014.

Taxpayers filing in Oregon and in states that have similar ‘tax haven’ statutes should ensure that they are in compliance with those laws. A careful review is required since the inclusion of ‘tax haven’ entities could yield a benefit or create additional liability depending on a taxpayer’s unique facts and special state income and sourcing rules.

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