Alabama Court of Appeals Upholds Denial of Consolidated Financial Institution Excise Tax Returns

The Alabama Court of Appeals affirmed the circuit court’s decision that taxpayers failed to meet the statutory requirements for filing consolidated Alabama Financial Institution Excise Tax returns. Taxpayers, a financial institution and its parent company, sought to file consolidated returns for tax years 2012 through 2020, but the Alabama Department of Revenue determined they were ineligible, resulting in additional tax liability and denial of refunds. The court found that the taxpayers failed the ownership test for years 2012-2018 because they omitted an intermediate holding company from their filings, breaking the required direct ownership chain, and failed the filing test for ...