Virginia Court Rules That Corporation Is Not Unitary with 17% Owned Limited Liability Company

The Virginia Court of Appeals has held that the Department of Taxation (“Department”) cannot require a corporation to include the income and factors of a 17% owned limited liability company with its own income and factors, demonstrating that entities taxed as partnerships are not always unitary regardless of a taxing agency’s position. Dep’t of Tax’n v. FJ Management, Inc., d/b/a FJI, Inc., Record No. 0701-23-2 (Nov. 12, 2024)....
By: Blank Rome LLP

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