On Jan. 24, the Maryland Court of Special Appeals held that two out-of-state intangible holding companies had corporate income tax nexus with Maryland because they were in a "unitary business" relationship with their Maryland parent company. In reaching this determination, the court emphasized the fact that the parent company deducted its payments that were treated as income by its intangible holding companies. The Court of Special Appeals reversed a circuit court decision that had canceled the tax assessments against the taxpayers and, in doing so, endorsed the Maryland Tax Court's original decision that upheld the Maryland comptroller's assessment against the intangible holding companies.
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