Google Unit’s South Carolina Tax Case Remanded After Law Change

A holding company within Alphabet Inc. failed to convince a South Carolina tribunal that the remedy for the tax department’s failure to comply with changes to the state’s corporate income tax law is to void the assessment.

Instead, the South Carolina Administrative Law Court remanded XXVI Holdings Inc.'s assessment challenge to the tax department for it to consider the intervening law change and the company’s opposition to the agency’s proposed alternative apportionment method.

“The practical effect” of XXVI’s request to void the assessment entirely “would be to adopt the state income tax liability as reported by Petitioner,” Administrative Law Judge ...