21 February 2017 State and Local Tax Weekly for February 10 Ernst & Young's State and Local Tax Weekly newsletter for February 10 is now available. Prepared by Ernst & Young's State and Local Taxation group, this weekly update summarizes important news, cases, and other developments in U.S. state and local taxation. Illinois Supreme Court rules Chicago's extension of lease transaction tax to suburban automobile renters unconstitutional In Hertz Corporation v. City of Chicago, widely known as the Enterprise case, the Supreme Court of Illinois (Court) determined that the City of Chicago's extraterritorial enforcement of its personal property lease transaction tax (lease tax) on short-term car rental companies doing business in and outside of Chicago on rental agreements executed outside of Chicago at a location that is within three miles of the City's border violates the home rule article of the State's constitution. The City of Chicago imposes a lease tax on leases of personal property used within the City's boundaries, or the privilege of using property in the City that was leased outside of the City. The transaction is exempt from the lease tax if the property is leased outside the City and primarily (defined as more than 50%) used outside of the City. In May 2011, the City's Department of Finance promulgated amended Ruling 11, requiring lessors of short-term car rentals doing business in the City to collect the tax for rental agreements executed within three miles of the City's border if the lessee was a Chicago resident, unless the lessee provided evidence that he/she intended to use the vehicle more than 50% outside of the City. The City created a presumption that short-term leases to a Chicago resident based on his or her billing address were for use within the City and subject to the tax, while non-resident lessees were presumed to have leased the vehicle for use outside of the City. The ruling also created a safe harbor provision for affected rental agencies, allowing them to assume that 25% of the rental charges to customers who are Chicago residents are for use in the City, and agencies could remit tax to the City on that amount. The key issue considered by the Court was whether the City improperly extended its home rule power to tax beyond its borders by requiring lessors to collect lease transaction tax from lessees who intended to use their vehicles primarily in Chicago during the rental period. While the Court agreed that the City has the authority to collect tax from taxpayers outside of its jurisdiction, it may only do so when the City has a sufficient connection with the location of the transaction. The City cited a number of instances in which taxpayers outside the City were required to collect tax on transactions inside the City, but the Court distinguished those cases from the present case, finding that the significant fact in those instances was the transactions being taxed all either occurred within the City's borders, or pertained to property delivered within the City's borders as directed by the taxpayers. The City contended the lessee's stated intent amounted to evidence of use inside the City and, therefore, is subject to tax so long as the lessor was aware of the stated intent. The Court found this unconvincing, noting a stated intention is merely evidence of intent, and not actual use. The City also argued the car rental companies were doing business in Chicago because, by opening locations close to Chicago, they were leasing vehicles the lessors knew would be used on a short-term basis in Chicago. The Court dismissed this argument on similar grounds. The Court ultimately decided that neither the residence of the lessee, nor the lessee's stated intent was an indication of where the rented vehicle was ultimately put to use. As such, Ruling 11 amounts to an extraterritorial tax on transactions that took place entirely outside of Chicago's borders. For additional information on this development, see Tax Alert 2017-305. Hawaii: Proposed bills (HB 1012 and SB 1228) would disallow for 15 years the dividends paid deduction (DPD) for real estate investment trusts (REITs) for tax years beginning after Dec. 31, 2017. A DPD, however, would be allowed for dividends generated from affordable housing properties. Under the Internal Revenue Code of 1986, as amended I, unlike other corporate taxpayers, a REIT may deduct dividends paid to its shareholders in calculating taxable income. In order for a REIT to claim the DPD, it must distribute 90% of its taxable income. "Taxable income" is calculated prior to DPD and excludes any net capital gain as well as net income from foreclosed properties. The rationale expressed by the Hawaii Department of Revenue for the change of law was that after much study, they determined that the investors in most REITs were not residents of Hawaii and otherwise were not paying state income tax on amounts earned by the REITs from real estate investments in the state. For additional information on this development, see Tax Alert 2017-297. Illinois: The Illinois Department of Revenue (Department) has filed proposed amendments to 86 Ill. Admin. Code § 100.3370, "Sales Factor ([Illinois Income Tax Act] IITA § 304)" (Regulation) with the Secretary of State, an action that commences a 45-day public commentary period. The Department's action is noteworthy, as the Regulation has not been amended since 2002 and does not comport with the 1999 and 2008 statutory enactment of market-based sourcing rules. While not aimed at insurance companies, financial organizations, regulated federal exchanges, and persons furnishing transportation services, the Regulation can, in certain instances, affect a financial organization. The proposed amendments to the Regulation contain technical corrections throughout and add substantive interpretive guidance on: (1) rules governing receipts from patents, copyrights, trademarks and other similar items of intangible personal property (statute enacted for tax years ending on or after Dec. 31, 1999); and (2) rules governing market-based sourcing (statute enacted for tax years ending on or after Dec. 31, 2008). In addition, the proposed amendments to the Regulation recognize the Illinois Supreme Court decision in Exelon Corp. v. Department of Revenue, 234 Ill 2d 266 (2009),by proposing a new paragraph to clarify that sales of electricity would not be considered sales of tangible personal property until tax years ending on or after July 15, 2009. For additional information on this development, see Tax Alert 2017-277. Indiana: An out-of-state corporation (corporation) that operates an Indiana manufacturing facility made a valid original decision to file an Indiana consolidated income tax return with a related out-of-state intellectual property holding company (IP Co) because the IP Co engaged in income-producing activity within Indiana by licensing its intellectual property to Indiana affiliates. Since the corporation properly filed original consolidated returns with the IP Co, it is allowed to file amended returns to include another related entity that was inadvertently omitted in the original filings. In regard to the IP Co, the Indiana Department of Revenue said that it "has long and consistently held that the exploitation and monetization of intellectual property within the state constitutes activities within Indiana giving rise to Indiana source income." Ind. Dept. of Rev., Letter of Findings 02-20160370R (Jan. 25, 2017). New Jersey: The New Jersey Division of Taxation (Division) cannot throw out a pharmaceutical company's receipts that are not sourced to any state, because other states' throwback rules and the pharmaceutical company's inventory storage in six states besides New Jersey provide legitimate grounds to reverse the Division's determination that only receipts reported to six states constitute the denominator of the pharmaceutical company's sales factor and the remainder become "nowhere sales" for purposes of New Jersey's throwout rule. In reaching this conclusion, the New Jersey Tax Court (Court) cited Whirlpool, finding that the taxpayer has the requisite contacts in some states to be taxable pursuant to the throwback rule, and some of the receipts were allocable to states where the pharmaceutical company stored its inventory (this activity is a constitutional basis for asserting nexus). The Court also cited Lorillard, which rejected that the Division should first ascertain whether the taxpayer filed returns and paid tax in the other states, finding that New Jersey's "only arguable interest" vis-à-vis the throwout rule is to exclude receipts from the denominator that other states cannot constitutionally tax or are so limited by federal law. Finally, it is irrelevant for purposes of the throwout rule whether California was the pharmaceutical company's principal place of business or management, because either California or New Jersey or both (on an apportionable basis) has/have the ability to tax the California receipts attributable to the sale of ABELCET, or other intangible income like interest and dividends, and this prevents those receipts from being thrown out of the denominator of the sales factor under Whirlpool. Elan Pharmaceuticals, Inc. v. N.J. Dir., Div. of Taxn., No. 010589-2010 (N.J. Tax Ct. Feb. 6, 2017) (unpublished). New York: A non-US banking organization's New York office is not a "branch" under former New York tax law (former Article 32, repealed effective Jan. 1, 2015) because it does not accept loan repayments on a regular and systematic basis as required by statute. Accordingly, it could not include deposits from the New York office in its deposits factor. The New York Department of Taxation and Finance (Department) explained that a "branch" is a bona fide office used by a taxpayer on a regular and systematic basis to: (1) approve loans, (2) accept loan repayments, (3) disburse funds, and (4) conduct one or more other functions of a banking business. The parties agreed that the New York office is used to disburse funds and conduct other banking business functions. Thus, the only issues are whether the New York office is used to approve loans and accept loan repayments. The Department determined that the New York office approves loans and that an exception to the general rule (under which a bank's office that is used to approve loans is not considered a branch if all of the office's loans are regularly and systematically reviewed and approved by another office) does not apply because some of the loans are reviewed for credit approval by staff members who work in the New York office. The New York office, however, does not qualify as a branch because it does not accept loan repayments. Instead, it requires all repayments be made to a deposit account in an unrelated US depository institution. N.Y. Dept. of Taxn. and Fin., TSB-A-16(7)C (Dec. 16, 2016). New York City: The "same source year rule" restricts the net operating losses (NOLs) a corporation can deduct for New York City General Corporation Tax (GCT) purposes to losses originating in the same tax years as the NOLs a taxpayer deducted for federal income tax purposes. In reaching this conclusion, the New York City Tax Appeals Tribunal Administrative Law Judge (ALJ) stated that the rule is derived from the statutory language limiting the NOL deduction for GCT purposes to "the deduction for the taxable year" under IRC § 172, and the same language appears in N.Y. Tax Law § 208.9(f)(3) governing the New York State Franchise Tax on Business Corporations (NYS BCT). The ALJ also cited Admin. Code §11-602.8(f)(5): "the net operating loss deduction … shall … be determined as if the taxpayer had elected … to relinquish the entire carryback period with respect to net operating losses, except with respect to the first $10,000 of each of such losses." In addition, the ALJ concluded that the New York City Department of Finance failed to meet its burden to prove that two IRC provisions (IRC §§ 170(d)(2)(B) and 172(b)(2), relating to NOLs and charitable contributions) did not apply to increase the available NOL carryovers to the tax years at issue, and further concluded that the corporation's charitable contributions for the years 2006 through 2009 must be taken into account in calculating the NOL deductions for the tax years because the corporation had previously included those on federal returns. The ALJ, however, disagreed with the corporation's application of IRC §170(d)(2)(B) to increase the NOL deduction for the 2009 tax year by the amount of the charitable contributions for the years 2006 through 2008, and provided a schedule showing the correct calculations. In the Matter of Plasmanet, Inc., No. TAT (E) 12-17 (GC) (N.Y.C. Tax App. Trib. Jan. 20, 2017). Ohio: Nonresident individuals properly treated S corporation income as nonbusiness income allocable to Missouri rather than business income apportionable to Ohio, because the income being taxed was a dividend paid out to the individual shareholders from previously accumulated C corporation earnings, rather than a "proportionate share" of the S corporation's own "business income." In reaching this conclusion, the Ohio Supreme Court (Court) found that the material distinction is the event that triggers a tax liability for the individual taxpayer, which was the declaration of the dividend, and not the S corporation's business activity. The Court noted that it previously made a misstatement in an applicable case, Agley, and should have stated there that the character of the S corporation shareholder's distributive share (rather than item distributed) of the corporation's own income is to be determined as if that income had been realized by the shareholder from the source from which the corporation realized the income. Ohio Rev. Code § 5747.231, which essentially codifies Agley, does not apply either, because the income taxed in this case is a dividend paid to the individual taxpayers from previously accumulated corporate earnings rather than a "proportionate share" of the S corporation's own "business income." Giddens et al. v. Testa, No. 2016-Ohio-8412 (Ohio S. Ct. Dec. 28, 2016). New Jersey: Vetoed bill (AB 4189) would have extended for two years the Urban Enterprise Zone (UEZ) programs in Bridgeton, Camden, Newark, Plainfield and Trenton. The UEZ programs in these cities expired on Dec. 31, 2016. The governor vetoed the bill on Feb. 10, 2017. For more on the expiration of these programs, see Tax Alert 2016-2053. New York: The fee that an online information services business (business) charges for reports analyzing a client's customers' habits and how to improve the client's customer base is subject to New York sales and use tax because the report incorporates client personal information and industry specific general information that is an integral part of the service. New York impose sales and use tax on the provision of information services, but provides an exclusion from tax for information that is personal or individual in nature and that is not or may not be substantially incorporated in reports furnished to other persons. The New York Department of Taxation and Finance (Department) determined that the exclusion does not apply to the business because a portion of the information in the reports comes from public sources, which are not uniquely personal or individual in nature. In addition, industry-specific information in the reports may be included in reports to similarly situated clients. The Department further stated that even when the information in the report is customized in some manner, it is still taxable if the information is substantially derived from common data sources. Finally, the business's use of non-personal information to provide reports is not de minimis, and instead is an integral component of the services, which compares its client's performance relative to its competitors performance and, therefore, is not "personal and individual" in nature. N.Y. Dept. of Taxn. and Fin., TSB-A-16(33)S (Dec. 7, 2016). Rhode Island: The Rhode Island Division of Taxation (Division) said that it is not feasible to issue a conditional tax exempt certification to a nonprofit organization awaiting a decision from the IRS on its tax-exempt status and, therefore, the nonprofit's purchases made prior to certification are subject to sales and use tax. The Division requires applicants for Rhode Island tax-exempt status to submit an application and their IRS 501(c)(3) determination letter to prove the charitable, educational or religious activities requested. The Division does not issue a conditional certificate during the review process because the review process may occur in a short period of time, and it will not allow a refund of sales tax for purchases made during the tax exempt review process. Once approved, the nonprofit organization must issue its exemption certificate to vendors when purchasing tangible personal property. R.I. Div. of Taxn., Ruling Request No. 2016-02 (Dec. 13, 2016). Texas: An out-of-state company charges for providing internet-based supply chain and purchasing services to the food service industry is subject to sales and use tax because these services qualify as taxable data processing. The company's services included receiving customers' electronic data, processing the data into required formats for the purpose of compiling and providing records of transactions (data manipulation), and maintaining data for use by customers. The Texas Comptroller of Public Accounts found that the essence of the services that the taxpayer provided was the processing and manipulation of data that was provided by the customers, and those are services that clearly fall within the definition of data processing services and are specifically excluded from the definition of information services. Tex. Comp. of Pub. Accts., Hearing No. 201609107H (Sept. 23, 2016). New York: A real estate developer and operator of diversified real estate projects (developer) that owns whole and partial stakes in various real estate development entities, is entitled to claim a qualified empire zone enterprise (QEZE) credit for real property taxes passed through from one of its development entities (FC Yonkers) because FC Yonkers' had one eligible employee to count in its employment number for the 2009 tax year. In reaching this conclusion, an administrative law judge (ALJ) of the New York Division of Tax Appeals determined that FC Yonkers' construction project manager, who worked in Pennsylvania as a common law employee of an affiliated entity during the year 2004, and worked as a common law employee of FC Yonkers from January 2005 through Jan. 31, 2009, can be included in FC Yonkers' computation of its employment number for the 2009 tax year because he was not employed within New York by a related person within the immediately preceding 60 months. Further, since FC Yonkers had a test year employment number of zero, its employment increase factor for 2009 tax year was one. In addition, certain payments that FC Yonkers made during 2009 qualify as "eligible real property taxes," entitling FC Yonkers to a refund. In addition, FC Yonkers' payment to a public benefit corporation pursuant to a 2007 Tax Benefit Leaseback Agreement qualifies because FC Yonkers is a certified QEZE and it made the payment in lieu of real property taxes to the public benefit corporation while construction on the development site was ongoing during 2009. A reimbursement payment from FC Yonkers to the public benefit corporation related to property located at Tuckahoe Road does not qualify as eligible real property taxes because there is no written lease under which the public benefit corporation leased the property to FC Yonkers, and the Tax Benefit Leaseback Agreement applies only to a different specific property. In addition, the ALJ found that waste disposal taxes qualify as eligible real property taxes because the waste disposal ta is plainly for the "general public welfare" and are imposed at a like rate against all property in the City of Yonkers. Sewer valuation charges, however, are special assessments and, as such, are not considered eligible real property tax. Finally, the frontage tax related to water mains does not qualify as an eligible real property tax for QEZE credit purposes because the presence of water mains and water supply available to service a property constitutes a benefit and the availability of water services enhances the property value. In the Matter of the Petition of Forest City Enterprises, Inc., No. 825917 (N.Y. Div. Tax App. Jan. 19, 2017). Indiana: A taxpayer's real property on which a daycare facility was located did not qualify for an educational purposes property tax exemption because the taxpayer did not provide, under the prominent use test, a time comparison of the amount of time the property was used for exempt educational purposes and used for a non-exempt purpose. In reaching this conclusion, the Indiana Tax Court (Court) noted that the Indiana Board of Tax Review's finding of fact that the daycare facility's provided activities that fostered an atmosphere of education cannot establish the property's predominant use (i.e., whether it was used more than 50% of the time for one or more exempt purposes) without a time-usage comparison. The taxpayer also did not qualify for the religious purposes exemption because, similarly, the taxpayer failed to identify or explain which of the daycare facility's activities furthered religious purposes, and did not provide a comparison of the amount of time spent daily on religious activities to the total amount of time the daycare facility operated each day. Hamilton County Assessor v. Duke, No. 49T10-1309-TA-00069 (Ind. Tax Ct. Feb. 3, 2017). Massachusetts: The Massachusetts Appellate Tax Board (Board) ruled in a central valuation case that municipalities failed to submit credible evidence indicating the value of the telephone company's Section 39 (centrally valued) property was significantly higher than the Revenue Commissioner's certified value for fiscal years 2005 through 2008. Therefore, the Board determined that the municipalities failed to meet their burden of proof, even though they correctly pointed out that intra-building cable should be included in the telephone company's centrally valued property. In cases of central assessment, the Commissioner determines the value of a telephone company's taxable "machinery, poles, wires and underground conduits, wires and pipes" on a municipality-by-municipality basis and certifies those values to the company and the appropriate boards of assessor. For fiscal year 2009, the telephone company included construction work in progress and aerial plant over public ways in its telephone/telegraph return. Citing Verizon II for fiscal year 2009, the Board found and ruled that the Commissioner's certified value of the telephone company's centrally valued property should be reduced by the value of its aerial plant over public ways, minus the value of its intra-building cable. Finally, citing the Verizon I and MCI appeals, the Board found that the Commissioner's methodology for centrally valuing telephone companies' Section 39 property (trended reproduction cost new less depreciation methodology) to be proper. Verizon New England, Inc. v. Mass. Comr. of Rev. and Bds. of Assessors of Belmont, Cambridge, Springfield and Worcester, Nos. C2730129 et al. (Mass. App. Tax Bd. Jan. 23, 2017). Alabama: Amended regulation (Ala. Admin. Code Reg. 810-3-24.2-.01) outlines circumstances under which pass-through entities may be relieved from making a composite payment on behalf of nonresident members, and provides guidance regarding tiered structures and the composite payment as well as the proper forms required to obtain relief. A tax-exempt entity may be excluded from the composite payment requirement by completion of Form NRC-Exempt attached to the entity's return in which the exemption is being claimed. Taxpayers may qualify for relief from the composite payment requirements on a case-by-case basis. Relief requests are made via Form PTE-R and must be received at least 30 days before the original filing date for the composite return. Under the Tiered Structure Indirect Owner Exception, a pass-through entity may, with the Alabama Department of Revenue's pre-approval, claim a composite payment exemption for an indirect owner (an owner of another pass-through entity that is itself an owner of the pass-through entity subject to the composite payment requirement). The pass-through entity must submit a Form NRC-Exempt executed by the indirect owner along with Form PTE-R and documentation adequate to show the portion of the pass-through entity's income flowing through to the direct owner. Other exemptions from the composite payment that do not require pre-approval include the following nonresident owners: (1) real estate investment trusts (REITs) that are not captive REITS and that have no Alabama-sourced income as a result of a dividends paid deduction, (2) nonresidents whose only Alabama-sourced income is derived from a capital credit project and the nonresident's capital credit is expected to fully offset any potential tax liability, (3) insurance companies that are subject to Alabama premiums tax and are exempt from income tax, and (4) a C-corporation that has been in a loss position for the three most recent tax years and expects to be in a loss position for the current tax year. Claiming such an exception requires the pass-through entity to include with its return Form NRC-Exempt executed by the nonresident owner. These changes take effect March 4, 2017. Ala. Dept. of Rev., Ala. Admin. Code §810-3-24.2-.01 (filed Jan. 18, 2017). All States: Panelists on the recent Current developments in state and local tax audits and controversy webcast by Ernst & Young LLP (EY) looked back at some of the biggest controversy developments of 2016, looked forward to what to expect in 2017, and discussed judicial administration issues with the Chief Judge of Alabama's Tax Tribunal William (Bill) C. Thompson on effective advocacy. The webcast is now available for replay on the EY Thought Center website. For a summary of the webcast, see Tax Alert 2017-288. New York: On Jan. 17, 2017, New York State Governor Andrew Cuomo released the 2018 New York State Executive Budget (Executive Budget) including proposed revenue legislation (the "2018 NY Budget Revenue Legislation"). If enacted, Parts JJ and KK of the 2018 NY Budget Revenue Legislation would expand the controlling interest transfer tax rules by amending the definition of "conveyance" for purposes of the Real Estate Transfer Tax (RETT) and change the manner in which the base for the tax (i.e., consideration) is calculated. The Governor's office estimates that the changes to the RETT law would result in additional annual revenue of $4 million for Fiscal Year 2018 and $5 million annually thereafter. Because of the unique way the RETT law is administered, these changes could have significant implications not only for direct transfers of real estate located in New York but also due to the sale or other transfer of stock of corporations or interests in partnerships, limited liability companies and other legal entities that own or lease, directly or indirectly, real property located in New York. For more on this development, see Tax Alert 2017-287. New York: The conveyance of real property from an "exchange accommodation titleholder" (EAT) to the exchangor as part of a "reverse" like-kind exchange under IRC §1031 is not subject to real estate transfer tax because the EAT is serving as the agent for the exchangor and no consideration is provided for the conveyance from the EAT to the exchangor. The New York State Department of Taxation and Finance found that the qualified exchange accommodation arrangement (QEAA) provides that all the property held by the EAT is being held for the benefit of the exchangor to facilitate the like-kind exchange and that the parties agree that the EAT is acting solely as the exchangor's agent for all purposes except for federal, and as appropriate, state income taxes. The EAT remains economically neutral under the QEAA terms, such as: (1) the EAT does not use any of its own funds to pay for the acquisitions of the properties; (2) it does not hold any responsibilities regarding property maintenance; (3) the EAT is paid only its fees for services and is held harmless in all other respects except income tax; (4) if the EAT acquires a replacement property and later leases the property to the exchangor prior to the conclusion of the exchange, the exchangor's rent paid to the EAT would equal any payment made by the EAT on a mortgage that secures a loan for the purchase price; and (5) the EAT does not report a gain or loss from the properties. N.Y. Dept. of Taxn. and Fin., TSB-A-16(2)R (Dec. 7, 2016). Oregon: Proposed joint resolution (SJR 41), if approved by voters, would amend the Oregon Constitution by providing for the imposition of a business privilege tax on gross receipts derived from Oregon sales. The tax would apply to all type of business entities organized in Oregon and may not have a marginal rate in excess of 0.7% of the taxpayer's gross receipts. Taxpayer's whose sales for the tax year are less than $5 million would pay a flat amount not to exceed $250 per tax year; and taxpayers whose sales are less than $150,000 would not be required to file a return. If SJR 41 is approved, this measure would be submitted for voter approval during a special election that would be held on May 16, 2017. SJR 41 was introduced on Feb. 13, 2017. Texas: The Texas Supreme Court (Court) held that former Public Utilities Regulatory Act (PURA) §36.060(a), which required an electric utility's income taxes be computed as though it had filed a consolidated return with a group of its affiliates eligible to do so under federal tax law, did not require a utility to adopt a corporate structure so as to be part of the group. In reaching this conclusion, the Court found that the Public Utilities Commission's (PUC) determination to calculate the utility's tax expense as if it were a corporation was not arbitrary or capricious because PURA §36.060 plainly applies only to a utility that is a member of an affiliated group eligible to file a consolidated tax return, not a utility that could be. It is the group that must be eligible to file a consolidated return, not the utility. The utility must be a member of an eligible group, and after November 2008, the utility was not. The Court also held that PURA §36.351, which requires electric utilities to discount charges for service provided to state college and university facilities, does not apply to a transmission and distribution utility (TDU) in deregulated areas because TDUs provide service to retail electric providers (REPs), not to the REPs' customers. Finally, the Court held that the evidence establishes that franchise charges negotiated by the TDU with various municipalities were reasonable and necessary operating expenses under PURA §33.008. Reading the paragraphs of PURA §33.008 together, the Court found that municipalities may continue to impose franchise charges after competition, that charges per kilowatt hour equal to the average amount charged in 1998 must be considered reasonable and necessary, and that utilities may continue to renegotiate franchise charges, though they must demonstrate that the charges are reasonable and necessary in order to pass them along to REPs. Oncor Electric Delivery Co. LLC, et al. v. Public Utility Co. of Texas, et al., No. 15-0005 (Tex. S. Ct. Jan. 6, 2017). Because the matters covered herein are complicated, State and Local Tax Weekly should not be regarded as offering a complete explanation and should not be used for making decisions. Any decision concerning matters covered herein should be reviewed with a qualified tax advisor. Document ID: 2017-0351 |
