Bloomberg Tax
Free Newsletter Sign Up
Login
BROWSE
Bloomberg Tax
Welcome
Login
Advanced Search Go
Free Newsletter Sign Up

Virginia Tax Commissioner Denies Taxpayer’s Request to Use Alternative Method of Allocating, Apportioning Partnerships’ Income

May 11, 2022, 5:00 AM

The Virginia Tax Commissioner Feb. 15 decided to uphold denials of Taxpayer’s requested corporate income tax refunds. Taxpayer was a nonprofit educational institution domiciled in Virginia and owned less than 10 percent limited partnership interests in various investment partnerships. Taxpayer effectively requested to use an alternative method of allocating and apportioning income. Taxpayer filed amended returns seeking refunds of tax paid on income attributable to the partnerships and not allocated to Virginia. The Department of Taxation denied the request. Taxpayer appealed, arguing against the partnership income being subject to Virginia income tax on grounds it was non-unitary investment function income. ...