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Berkshire Unit Denied Investment Tax Credit in Connecticut Court

June 28, 2022, 4:29 PM

An electrical systems manufacturer isn’t entitled to a tax credit for fixed capital investments made by its two subsidiaries, a Connecticut trial court has ruled.

Marmon Wire & Cable Inc. sought fixed capital investment credits for tax years 2016 and 2017 for purchases made by two wholly-owned limited liability companies, RSCC Wire & Cable LLC and Marmon Utility LLC. Marmon Wire’s ultimate parent is Berkshire Hathaway Inc.

Entities that are disregarded for tax purposes, such as the subsidiaries here, are treated in the same way as a division of the owner, except that they are treated as separate ...