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Court of Appeals of South Carolina
Uncategorized

Mt. Pleasant Investments v. Charleston County Assessor — ATI Exemption Caps Tax Value at Pre-Sale Baseline, Not Pre-Sale Plus Pre-ATI Improvements

The South Carolina Court of Appeals reversed the Administrative Law Court’s property tax ruling, holding that the “current fair market value” floor for the ATI exemption is the pre-sale value on the assessor’s books—not that value inflated by improvements the prior owner completed before the sale closed. Because the improvements were already incorporated into the ATI fair market value of $8,034,000 used to compute the exemption value, the Assessor’s approach of re-adding them to the current fair market value floor impermissibly double-counted them. The taxable value for tax year 2022 was $6,063,000, not $6,821,000.

Court of Appeals of South Carolina
Uncategorized

Tractor Supply Co. v. SCDOR — Court Upholds Combined Unitary Reporting for South Carolina Corporate Tax

The South Carolina Court of Appeals affirmed the Administrative Law Court’s approval of combined unitary reporting (CUR) as the Department of Revenue’s alternative apportionment method for Tractor Supply Company’s 2014–2016 tax years, holding that artificially inflated intercompany transfer pricing that shifted income to a non-filing affiliate distorted the standard sales factor formula, and that CUR is an authorized and reasonable remedy under § 12-6-2320(A) and Media General.

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