Transcription of Addback: It’s Payback Time - barnwellco.com
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Addback: It’s Payback Time - barnwellco.com
addback : It s Payback Timeby Charles F. Barnwell, 2000, 18 states have enacted addback rulesto curb perceived taxpayer abuses based on the useof interest and intangible-related expenses betweenrelated parties. Generally, those antiabuse statutesrequire the payer of related-party interest, royalties,license fees, and similar charges to add back thoseexpenses. Every state has some exceptions to therequired addback , and those exceptions are dis-cussed in detail in this , the states failed to act uniformlyand the rules have significant differences. Thosedifferences are often subtle and can result in confu-sion and conflicts from state to state.
to intangibles; that is, the commission sought to di-rectly tax an intangible holding company located in Delaware.6 In contrast, Georgia sought to disallow Aaron’s royalty payments to its wholly owned sub-
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