The authors review state interest and intangible expense addback provisions. The presence of exceptions to addback requirements is a tacit recognition that addbacks are blunt instruments of state tax policy, the authors say. Most states with addback provisions require an analysis of the business...

The authors write that a new paradigm for tax planning has developed. This paradigm emphasizes the economics underlying tax-planning transactions. The new paradigm requires a more collaborative form of planning, in which different advisers, both internal and external, play different roles

The authors examine state strategies for curbing some kinds of tax planning. Although the change in the state tax planning environment may cause the extinction of certain one size fits all tax planning strategies, individualized state tax planning strategies that are based on valid, achievable...