might be able to reduce Target's surplus for purposes of the Texas Franchise Tax. To avoid this, the taxpayer should argue that the new debt of Target to Holding is merely a recapitalization of Target. For example, if when a corporation started doing business in a state it had a debt equity ratio of 50 percent, and had always had such a ratio, the interest paid to service that debt would surely be considered a business expense. The result should be no different if a corporation changes its debt equity ratio, for example, from 50 percent to 60 percent. 2. Combined Reporting. In jurisdictions where combined reporting of corporations entails applying a single combined apportionment formula to a single combined income figure (sometimes called state "consolidated" returns), the use of push down accounting might not be necessary inasmuch as the problem that push down accounting is intended to mitigate me offsetting of Target's income with Holding's interest expense can be addressed by the filing of a combined return; a taxpayer should not encounter any problems in using the interest payments to offset Target's income in those states that permit taxpayers, in either a de jure or a de facto manner, to elect combination. See Colorado (Colo. Rev. Stat. [sections] 39 22 305(1) (1996), but see Reg. [sections] 39 22 305. 3); Arizona (Ariz.
FTB LEXIS 30 (Nov. 29, 1995); Legal Ruling 95 8, 1995 Cal.
debt refinancing and debt reduction, and by virtue of large tax loss carry forwards owned by the holding company which are utilized by the operating subsidiary. " See also Gam Rad West, Inc. , State Board of Womens Nike Air Max 2015 Black/White/Hyper Punch/Grape
Rev. Stat. [sections] 43 947 (1996)). In The First National Bank of Manhattan v. Kansas, 779 P. 2d 457 (Kan. Ct. App. 1989), the Kansas Court of Appeals determined that a holding company formed for the purpose of holding the stock of a bank, which had no employees or officers and owned virtually no property, was not involved in a unitary business with its subsidiary bank. The facts in this case are particularly relevant since the holding company's only activity was the paying off of debt that it had incurred in acquiring the stock of its subsidiary bank; the holding company received the money with which to pay off its debt from dividends distributed by the bank. Womens Air Max 2016 After years of uncertainty in California, the State Board of Equalization issued a determination in which it held that a passive holding company could be engaged in a unitary business with its subsidiaries. Matter of PBS Building Systems, Inc.
FTB LEXIS 31 (.
, State Board of Equalization, Nos. 89A 1014 and 89Aa 1015, 1994 Cal. Tax LEXIS 434 (Nov. 17, 1994). The Board further concluded that such a determination is to be made by use of the standard method used to determine the presence of a unitary business. The Board specified that in a holding company situation, "[c]onsiderable unity of operation may exist, for example by virtue of intercompany financing, including loans, loan guarantees, Womens Nike Air Max Pink And Black
Equalization, 1996 Cal. Tax LEXIS 257 (Sept. 11, 1996); Legal Ruling 95 7, 1995 Cal. Nike Air Max For Womens 2015 Price
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