Oregon Tax Court — Entities not unitary without centralized management, de minimis in-state activity is not ‘doing business’

May 2014


The Oregon Tax Court held that shared officers among related entities did not satisfy the unitary requirement of centralized management or executive force. Additionally, an out-of-state entity was not ‘doing business’ in Oregon for Corporation Excise Tax purposes when two of its employees spent a total of four days in the state inspecting franchisee operations and providing training. Finally, a captive insurance company was unitary with its parent’s combined group due to the economies of scale enjoyed by the group. 

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