New York – Group deemed non-unitary, combination denied

April 2014


A New York administrative law judge concluded that a corporate group was not engaged in a unitary business, notwithstanding numerous unreimbursed services provided by the parent to the subsidiaries. In ruling that the entities did not exhibit the requisite flow of value, the ALJ drew a distinction between management oversight activities versus centralized management based on operational expertise. Thus, the group’s attempt to file on a combined basis so as to prevent distortion was rejected.

Return to Tax research and insights

Contact us

Peter Michalowski
National SALT Practice Leader
Tel: +1 (646) 471 5259

Follow us