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Maryland Tax Court again subjects affiliated taxpayers to corporate income tax with fair apportionment

The Maryland Tax Court has determined that a multistate retailer and its subsidiary engaged in substantial intercompany transactions with each other, as well as other members of an affiliated group, were subject to Maryland corporation income taxes. Following several precedential decisions of Maryland courts based on similar fact patterns, the court ruled that the retailer and subsidiary had nexus with the state, and the Maryland comptroller fairly apportioned income to the retailer and subsidiary based on income-producing activities that occurred in Maryland.

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