Bruce P. Ely Quoted in State Tax Notes Regarding MUCR in 2016
State Tax Notes
State and Local Tax (SALT) partner Bruce Ely was quoted in State Tax Notes in regards to Alabama lawmakers considering another move toward mandatory unitary combined reporting (MUCR) in 2016.
"The Department of Revenue tried to sell [an MUCR] bill as a simplistic solution to a very complicated issue," said Ely. "For example, the heads-I-win-and-tails-you-lose clause provides that if Company A has profits while unitary Company B has losses, those losses cannot be claimed by the unitary group, but only by the company that initially suffered the losses. The same policy would apply to tax credit. Not so if both companies had profits. That's just awful tax policy."
"The Department of Revenue tried to sell [an MUCR] bill as a simplistic solution to a very complicated issue," said Ely. "For example, the heads-I-win-and-tails-you-lose clause provides that if Company A has profits while unitary Company B has losses, those losses cannot be claimed by the unitary group, but only by the company that initially suffered the losses. The same policy would apply to tax credit. Not so if both companies had profits. That's just awful tax policy."
