Leveraging Addbacks of Related-Party Royalties, Interest and Expenses in 2013

Responding to Latest State Laws, Regs and Rulings Affecting Multi-State Companies

Recording of a 110-minute CPE webinar with Q&A

Conducted on Wednesday, September 11, 2013

Recorded event now available

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Program Materials

This teleconference will provide state tax specialists with a bottom-line briefing on what's happening with the related-party addback agenda for multi-state corporations, looking at state and major local laws, regulations, and court and agency rulings. The panel will also address emerging, sophisticated variations on the intangibles structures.

Description

Multi-state companies and their tax staffs never stop wrestling with new developments in related-party addbacks of royalties, interest and other expenses arising from trademarks, trade names, patents and other intangible assets several years after a major flurry of new state laws and court rulings.

For example, New York's latest budget bill revises the royalty addback rules for the state and New York City. Pennsylvania's House approved a tougher addback measure, but Oregon killed related-party addback as of 2013. A key court ruling in Wendy's International held for the taxpayer on royalty addbacks.

Meanwhile, other related-party expense battles are percolating through state courts, and key administrative rulings and guidance were issued by states such as Tennessee and Kentucky. Clearly, companies that navigate state tax implications of their use of IP and other intangibles cannot let their guard down.

Listen as our panel of state tax advisors brings you current on impactful developments involving related-party addbacks about which you may have been unaware, and explains their bottom line for multi-state corporate taxpayers.

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Outline

  1. Report on recent state addback laws
    1. New York
    2. Oregon
    3. Pennsylvania
    4. Others
    5. Bottom line for corporate taxpayers
  2. Court decisions of note
    1. Wendy's International decision in Virginia
    2. Other addback cases recently filed in courts
    3. Bottom line for corporate taxpayers
  3. State agency rulings and administrative guidance of note
    1. Tennessee, Kentucky and others

Benefits

The panel will review address important issues such as:

  • Latest actions on addbacks in legislatures, courts and revenue agencies.
  • State law changes that have made it tougher for companies to utilize intangible assets with related entities without taking a tax hit.
  • States that have relaxed their positions on related-party addbacks.
  • Special disclosures now required on addbacks.

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.

Faculty

Scott Smith
Scott Smith
Of Counsel
Baker Donelson Bearman Caldwell & Berkowitz

Mr. Smith is attached to the firm’s Tax Department and has more than 20 years of federal, state and local tax...  |  Read More

Maria Todorova
Maria Todorova
Atty
Sutherland Asbill & Brennan

Ms. Todorova is attached to the firm's Tax Practice Group, focusing on state and local tax matters. She works on...  |  Read More

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