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Post details: Massachusetts --Corporate Income Tax: Limited Partnership Interest Served Operational Function
09/13/07
Massachusetts --Corporate Income Tax: Limited Partnership Interest Served Operational Function
CCH (cch.taxgroup.com) reports:
The income from an out-of-state corporation's distributive share of a limited partnership was subject to apportionment for Massachusetts corporate excise tax purposes and not subject to a 100% allocation of the income to the state. The corporation was entitled to an abatement of tax after the apportionment of the income from the limited partnership interest because the business activities of the limited partnership were closely related to that of the corporation and served an operational not passive investment function. Because other jurisdictions in which the corporation conducted business operations were entitled to tax an apportioned share of the limited partnership interest, a 100% allocation of the income to Massachusetts was improper.
Sasol North America v. Commissioner of Revenue , Massachusetts Appellate Tax Board, No. C273084, September 5, 2007, ¶401-101
Other References:
Explanations at ¶11-520
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