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Columbia Sportswear USA Cop. v. Indiana Department of State Revenue

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The Utah Tax Court recently issued its decision in Seeā€™s Candies, Inc. v. Utah State Tax Commission, Case No. 140401556, holding that the ā€œarmā€™s-lengthā€ standard set forth in the federal treasury regulations relating to section 482 of the Internal Revenue Code (ā€œIRCā€) controls for purposes of guiding the Utah State Tax Commission (ā€œCommissionā€) in reallocating income pursuant to Utah Code section 59-7-113 (ā€œSection 59-7-113ā€), which is nearly identical to section 482 of the IRC.