721.8 kB - Poledna | Boss | Kurer

ConnecticutGeorgiaIllinoisIndianaRecipient’s incomeis taxed by a foreigncountry• Interest expense—Transactionhas business purpose otherthan tax avoidance, is conductedat arm’s length, andincome is taxed by a foreigncountry at rate within 3 percentagepoints of CT rate• Interest expense—Recipientis located in foreign countrywith U.S. tax treatyTransaction has business purpose,amount is arm’s length,and recipient is domiciled inforeign country with U.S. taxtreatyIncome is taxed by a foreigncountryPrincipal purpose of transactionis not tax avoidance,amount is arm’s length, andincome is taxed by a U.S.possession or foreign countrythat is recipient’s commercialdomicileRecipient’s incomeis taxed by a U.S.state Conduit payment OtherInterest expense—Transactionhas business purposeother than tax avoidance,is conducted at arm’slength, and income istaxed by a state at ratewithin 3 percentage pointsof CT rateTransaction is arm’slength, and income istaxed by a stateIncome is taxed by a statethat does not mandateunitary reportingPrincipal purpose oftransaction is not taxavoidance, amount isarm’s length, and incomeis taxed by a state thatis recipient’s commercialdomicileTransaction has business purpose,and recipient pays expenses tounrelated third party in same yearPrincipal purpose of transaction isnot tax avoidance, and recipientpays expenses to unrelated thirdparty in same year• Principal purpose of transactionis not tax avoidance, and recipientpays expenses to unrelatedthird party in same year• Principal purpose of transactionis not tax avoidance, taxpayerreceives amount from unrelatedthird party, and taxpayerpays expenses in arm’s-lengthtransaction• Adjustment is unreasonable• Taxpayer agrees to alternateadjustment• Taxpayer elects to compute CTtax on unitary basisTaxpayer agrees to alternateadjustment• Adjustment is unreasonable• Taxpayer agrees to alternateadjustment• Principal purpose of transaction isnot tax avoidance, and amount isarm’s length• Taxpayer receives dividend frompayee• Adjustment is unreasonable• Taxpayer agrees to alternateadjustment• Taxpayer and recipient file INcombined or consolidated return• Principal purpose of transaction isnot tax avoidance, and recipientregularly engages in transactionsinvolving intangibles with unrelatedmembers on similar terms• Principal purpose of transaction isnot tax avoidance, amount is arm’slength, and recipient is engagedin substantial business activitiesinvolving intangibles or other substantialbusiness activitiesKentuckyMarylandIncome is taxed by a foreigncountry, amount is arm’slength, and recipient is engagedin substantial businessactivities (unrelated to intangiblesor financing of relatedmembers) that require officesand full-time employeesPrincipal purpose of transactionis not tax avoidance, amount isarm’s length, and income is taxedby a U.S. possession or foreigncountry with U.S. tax treaty ataggregate effective tax rate of4% or moreIncome is taxed by a state,amount is arm’s length,and recipient is engagedin substantial businessactivities (unrelated tointangibles or financing ofrelated members) that requireoffices and full-timeemployeesPrincipal purpose of transactionis not tax avoidance,amount is arm’slength, and income istaxed by a state at aggregateeffective tax rate of4% or morePrincipal purpose of transactionis not tax avoidance, amount isarm’s length, and recipient paysexpense to unrelated third partyin same year• Taxpayer agrees to alternateadjustment• Taxpayer and recipient includedin KY consolidated return• Recipient engages in transactionswith unrelated members on identicalterms• Management fees—Amount isarm’s lengthInterest expense—Tax avoidance isnot principal purpose of transaction,amount is arm’s length, andtaxpayer and recipient are banks43