In this quarter's publication, we highlight the following significant developments:
- New York's tax reform and the reform's combination rules, credits and incentives changes, and impact on manufacturers and asset management companies.
- Rhode Island's mandatory unitary combined reporting, tax rate reduction, tax haven treatment, single sales factor apportionment, and repeal of related party expense addback.
- Tennessee's Vodafone decision ruling that the Commissioner could apply a market-based alternative apportionment method against a taxpayer that followed the state’s statutory cost of performance sourcing rules.
- Massachusetts' National Grid decision, which reviewed the substance of transactions between two related entities and recharacterized proposed debt treatment as equity.
We also provide a summary of all PwC state tax Insights issued from April to June 2014. Each item is linked to a Insight that provides analysis and observations regarding the development.