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Maryland Circuit Court affirms intangible holding company had corporate income tax nexus

The Maryland Circuit Court for Anne Arundel County recently affirmed a Maryland Tax Court decision holding that an out-of-state intangible holding company had corporate income tax nexus with Maryland because it was considered to have no real economic substance as a business entity separate from its parent company. In affirming the Tax Court, the Circuit Court agreed that a Maryland Court of Appeals decision, Gore Enterprise Holdings Inc. v. Comptroller of the Treasury, was factually similar to the instant case and must be followed.

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