Articles Posted in New Mexico

The New Mexico Court of Appeals has held that a multinational oil and gas production company did not constitute a “unitary corporation” with its foreign subsidiaries, pursuant to statutory carve-out language regarding the term “unitary corporation.” Taxpayer Apache Corporation’s (Taxpayer) foreign subsidiaries issued dividends, generated Subpart F income, or otherwise…

A New Mexico Hearing Officer found that Gross Receipts Tax does not apply to a taxpayer’s markup for services performed outside New Mexico, but the taxpayer’s reimbursements for payroll to New Mexico employees are taxable New Mexico receipts.  In Protest of Talbridge, the taxpayer was a Texas employment agency with…