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Home / Opinion Digests / Business Law / SCV: “Add-back” exception only for income actually taxed (access required)

SCV: “Add-back” exception only for income actually taxed (access required)

Rather than construing an ambiguous tax statute against the Commonwealth, the “add-back” statute intended to close a loophole – wherein a corporate entity pays royalties to an affiliated intangible holding company – required a national retail store to count such royalties as income unless actually taxed by another state. Background Appellant Kohl’s Department Stores Inc. operates retail ...