![]() The Tax Court concluded that the affiliates were subject to the corporate income tax, and taxpayer appealed to the Oregon Supreme Court. In proceedings before the Tax Court, the department alleged for the first time that the affiliates were alternatively subject to Oregon’s corporate income tax. The Department of Revenue issued notices of deficiency for tax years 2006 through 2008, alleging that the affiliates were subject to Oregon’s corporate excise tax. Case Summary: Taxpayer filed consolidated income tax returns for a group that included two corporate affiliates that did not have a physical presence in this state. The judgment of the Tax Court is affirmed. Rosenblum, Attorney General Benjamin Gutman, Solicitor General and Darren Weirnick and Peenesh H. Cunningham, Assistant Attorney General, Salem, argued the cause and filed the brief for respondent. Markley, Perkins Coie, LLP, Portland, argued the cause and filed the briefs for appellant. (TC 5197) (SC S064803) En Banc On appeal from the Oregon Tax Court.* Henry C. DEPARTMENT OF REVENUE, Defendant-Respondent. 44 Aug441 IN THE SUPREME COURT OF THE STATE OF OREGON CAPITAL ONE AUTO FINANCE INC., Plaintiff-Appellant, v. The Oregon Supreme Court concluded: (1) the department timely raised the corporate income tax issue and (2) the corporate affiliates were subject to the corporate income tax based on “income derived from sources within this state.” Ruling on cross-motions for summary judgment, the Tax Court concluded that the affiliates were subject to the corporate income tax and entered judgment in favor of the department. Preliminarily, taxpayer also asserted the department lacked the authority to assert for the first time in the Tax Court that the affiliates were subject to corporate income tax. Ultimately, the issue in this case was whether taxpayer’s corporate affiliates, which did not have a physical presence in this state, were subject to either Oregon’s corporate excise tax or its corporate income tax for the tax years 2006-2008. ![]() Taxpayer disputed the Department of Revenue’s contention that it owed additional taxes. ![]() (taxpayer) filed consolidated Oregon corporate excise tax returns as part of a group that included two corporate affiliates. Fairbank served on MasterCard International’s Global Board of Directors from February 2004 until May 2006.Capital One Auto Finance, Inc. Fairbank was Vice President and head of the banking practice at a national strategy consulting firm. Fairbank has extensive experience in financial services and has led the development, growth, and transformation of the Company’s business capabilities since its founding, including technology, risk management, brand, customer experience, and talent development and diversity. Fairbank has been responsible for overseeing both the Company’s strategic direction as well as management of Capital One’s day-to-day operations, and has driven strong organic business growth and executed a series of strategic acquisitions across retail and direct banking, credit cards, auto lending, and technology. Fairbank has been the CEO since the Company’s Initial Public Offering in November 1994 and has served as the Chairman and CEO since February 1995. Fairbank has grown Capital One from a start-up to one of the ten largest banks in America and 100 largest companies in the country as ranked by Fortune Magazine. As an innovator and entrepreneurial leader, Mr. Fairbank is founder, Chairman, Chief Executive Officer, and President of Capital One Financial Corporation. ![]()
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