HMB Provides Comments to the South Carolina Department of
Revenue on Proposed Alternative Apportionment Guidance
May 14, 2015
In response to the South
Carolina Department of Revenue's recent call for comments
on both a proposed revenue ruling and revenue procedure regarding
alternative apportionment and combined
reporting, HMB recently submitted a
letter outlining its concerns with the draft guidance.
The purpose of HMB's comments was to highlight for the Department
the importance that any guidance regarding alternative
apportionment be geared to ensure uniform, consistent, and
transparent administration of tax. While alternative apportionment
can be an extremely important tool for both taxpayers and
departments of revenue alike, as Chris
Lutz and Breen
Schiller outlined in their two-part article for
State Tax Notes, it is all too often used to undermine
the due process rights of taxpayers. It is HMB's hope that the
South Carolina Department of Revenue appreciates this concern and
that any final guidance serve to improve, rather than hinder, the
business environment in South Carolina.
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