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Examining Unitary Business in a State Tax Dispute

In Philip Morris USA v. Department of Treasury (Michigan Court of Claims), Brattle was retained by Altria Group Inc. to advise the taxpayer on the taxation of extraterritorial investment gains. Brattle worked closely with counsel and the finance team to undertake a detailed functional analysis and prepare an assessment of the unitary nature of the businesses at issue. The state tax authority conceded the matter.

Practices
Tax Controversy & Transfer Pricing
Tax Controversy & Transfer Pricing

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