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North Carolina: Trial Court Reverses ALJ Holding that Disallowing Related-Party Deductions was Unconstitutional

A North Carolina trial court reversed an administrative law judge’s (ALJ) ruling in a case involving a taxpayer’s North Carolina corporate franchise tax liability computed under the capital stock base wherein the ALJ held that denying the taxpayer deductions for certain intercompany loan receivables owed by its affiliates not doing business in North Carolina would violate the dormant Commerce Clause.

Source Deloitte

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