Knowledge Center

Thursday, May 14, 2015

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alternative apportionment and combined reporting, HMB recently submitted a letter outlining its concerns with the draft guidance.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.

Alternative Apportionment and the Erosion of Due Process, Part 1
Alternative Apportionment and the Erosion of Due Process, Part 2


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