Sutherland Tax Partner Michele Borens comments on the Maryland Tax Court's decision in W.L. Gore & Associates Inc. v. Maryland Comptroller of the Treasury in which the court upheld income tax assessments against two Delaware intangible holding companies that lacked physical presence in the state. The court found that the companies had substantial connections and nexus by virtue of the activities of their parent company. Borens stressed that the court's ruling was flawed and noted the following: "The Maryland Tax Court's decision in Gore muddles multiple distinct state tax concepts—the unitary business principle, economic substance and nexus principles."
Eversheds Sutherland is an international law firm helping the Fortune 100, industry leaders, sector innovators and business entrepreneurs solve their biggest challenges and reach their business goals. Dedicated to unfaltering excellence in client service, we are known for our business savvy and industry intelligence, providing creative and custom solutions for each of our clients. Industry and business experience makes the difference for our clients.
Complete the fields below to send your briefcase via email. Separate multiple email addresses with semi-colons(;)