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Minnesota Tax Court affirms financial institution’s apportionment planning by denying commissioner’s alternative method

On April 18, 2017, the Minnesota Tax Court overturned the Minnesota Commissioner of Revenue’s alternative apportionment order and affirmed a financial institution’s treatment of captive partnerships as non-financial institutions for apportionment purposes for the 2007 and 2008 tax years. The commissioner did not meet the burden of proof necessary to apply an alternative apportionment method because she failed to show that the standard apportionment formula did not fairly and correctly apportion the taxpayer’s income to Minnesota.

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