Legal Opinion

Kohl's Dep't Stores, Inc. v. Va. Dep't of Taxation

Supreme Court of Virginia

Decided August 31, 2017No. Record 160681PublishedCited by 2 opinions

1Opinion of the Court

OPINION BY JUSTICE WILLIAM C. MIMS

In this appeal, we consider the extent to which a corporate taxpayer must include in its Virginia taxable income royalties paid to an intangible holding company.

I. Background and Procedural History

Kohl's Department Stores, Inc. ("Kohl's") is a corporation organized under the laws of Delaware. It operates retail stores throughout the United States, including Virginia. Kohl's Illinois, Inc. ("Kohl's Illinois"), a corporation organized under the laws of Nevada, is an affiliate of Kohl's. Kohl's Illinois operates retail stores in select states, none of which are…

Also in this document: Dissent.

2Cases cited22 opinions

Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
Swift & Co. v. Hocking Valley Railway Co.Supreme Court of the United States · 1917
Allied-Signal, Inc. Ex Rel. Bendix Corp. v. Director, Division of TaxationSupreme Court of the United States · 1992
ASARCO Inc. v. Idaho State Tax CommissionSupreme Court of the United States · 1982

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3Cited by2 opinions

Kohl'S Dep't Stores, Inc. v. Va. Dep't of TaxationSupreme Court of Virginia · 2018
Terrance Kevin Hall v. Commonwealth of VirginiaCourt of Appeals of Virginia · 2018