Oregon Tax Court - Substantial nexus for corporate excise tax and income tax may be established by economic presence

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January 2017


On August 9, 2018, the Oregon Supreme Court upheld the Oregon Tax Court decision.


On December 23, 2016, an Oregon Tax Court concluded, on partial summary judgment, that substantial nexus for the Oregon corporate excise and income tax may be established by economic presence. In this case, entities with no physical presence lent money, charged fees, and pursued debt enforcement measures against Oregon customers. The character, number, and purposefulness of these transactions led the tax court to conclude that the entities were subject to income taxation.

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Peter Michalowski

Peter Michalowski

State and Local Tax Leader, PwC US

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