A Murphy Oil subsidiary is entitled to a nearly $4 million tax refund because it properly allocated certain interest expenses related to a corporate spin-off to its domicile state of Arkansas, the state’s high court said.
Under the Uniform Division of Income for Tax Purposes Act, income generated through atypical activity must be completely allocated to the state of domicile, the Arkansas Supreme Court said. The state supreme court refused to reverse a lower court’s finding and rejected the Arkansas Department of Finance and Administration’s three alternative arguments.
In 2013, Murphy Oil USA spun-off its previous parent company
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