Speakers: David J. Gutowski Kyle O. Sollie

Event Type: Teleseminar

Location Name:
Teleseminar
Start Date/Time:
17 August 2011
End Date/Time:
17 August 2011

Huh? Making Sense of the New Jersey Supreme Court's Throwout Decision

On July 28, the New Jersey Supreme Court upheld the constitutionality of throwout, yet limited throwout to only certain types of receipts. The ruling leaves several issues unresolved.

On Wednesday, August 17, 2011 at 12:00 EDT, Reed Smith lawyers, David Gutowski and Kyle Sollie, discussed the ruling via teleseminar, including:

  • Who are the winners and losers?
  • How should taxpayers report throwout (if at all) on their 2010 returns?
  • Does throwout still apply in states where a taxpayer is protected by P.L. 86-272?
  • Whose nexus standards are used to determine whether another state has jurisdiction over a taxpayer?
  • Will IHCs necessarily see their tax go down?
  • How does this ruling affect previously executed closing agreements?
  • Does the court's ruling mean that most taxpayers can fully deduct interest paid to affiliates?
  • To the extent throwout still applies, what happens next for as-applied challenges?