X

Thank you for sharing!

Your article was successfully shared with the contacts you provided.

The full case caption appears at the end of this opinion.This dispute between Simpson Investment Company (Simpson) andthe State Department of Revenue (Department) presents the question ofwhether Simpson, a holding corporation for multiple subsidiaries, is a’financial business’ for purposes of RCW 82.04.4281 (section 4281).Section 4281 provides a Business and Occupational (B&O) tax deduction forthe investment income of all persons not ‘engaging in banking, loan,security, or other financial businesses.’ RCW 82.04.4281. The Departmentassessed B&O taxes against Simpson, claiming it was not entitled to deductits investment income because it is a ‘financial business.’ Simpsoncontested this assessment in a refund action, culminating in motions forsummary judgment. The Thurston County Superior Court denied Simpson’smotion, granting summary judgment to the Department, and Simpson appealed.The Court of Appeals reversed, determining that Simpson is not a ‘financialbusiness’ and is therefore entitled to deduct its investment income incalculating its B&O tax liability. Simpson Inv. Co. v. Department ofRevenue, 92 Wn. App. 905, 965 P.2d 654 (1998). We find that Simpson is afinancial business and reverse the Court of Appeals.

FACTS

 
Reprints & Licensing
Mentioned in a Law.com story?

License our industry-leading legal content to extend your thought leadership and build your brand.

More From ALM

Premium Subscription

With this subscription you will receive unlimited access to high quality, online, on-demand premium content from well-respected faculty in the legal industry. This is perfect for attorneys licensed in multiple jurisdictions or for attorneys that have fulfilled their CLE requirement but need to access resourceful information for their practice areas.
View Now

Team Accounts

Our Team Account subscription service is for legal teams of four or more attorneys. Each attorney is granted unlimited access to high quality, on-demand premium content from well-respected faculty in the legal industry along with administrative access to easily manage CLE for the entire team.
View Now

Bundle Subscriptions

Gain access to some of the most knowledgeable and experienced attorneys with our 2 bundle options! Our Compliance bundles are curated by CLE Counselors and include current legal topics and challenges within the industry. Our second option allows you to build your bundle and strategically select the content that pertains to your needs. Both options are priced the same.
View Now

Elite Trial Lawyers 2021

July 29, 2021
Virtual

The National Law Journal Elite Trial Lawyers recognizes U.S.-based law firms performing exemplary work on behalf of plaintiffs.


Register

BenefitsPRO Broker Expo 2021

May 18, 2021 - August 18, 2021
Virtual / San Diego, CA

The premier educational and networking event for employee benefits brokers and agents.


Register

African Legal Awards 2021

September 03, 2021
TBD

The African Legal Awards are set out to recognise exceptional achievement from Africa s legal elite.


Register

Legal Secretary- Experienced

Miami, Florida, United States

Miami Law Firm seeks experienced Legal Secretary withminimum 5+ years experience in Plaintiff's Personal Injury.Computer literate. Must be f...


Apply Now ›

LEGAL ASSISTANT

Atlanta, Georgia, United States

Our boutique Plaintiffs' firm based in Sandy Springs is in need of a legal assistant with 3+ years experience.  A large percentage of o...


Apply Now ›

Senior Attorney

Long Island City, New York, United States

NEW YORK CITY SCHOOL CONSTRUCTION AUTHORITY                 ...


Apply Now ›

VAN DER VEEN, O NEILL, HARTSHORN, AND LEVIN

07/27/2021
TLI Web

VAN DER VEEN, O NEILL, HARTSHORN, AND LEVIN is pleased to welcome Frank Breitman, Esq. a talented and respected litigator to our ranks of trial lawyers.


View Announcement ›

HARWOOD LLOYD, LLC

07/26/2021
NJLJ Web

HARWOOD LLOYD, LLC Welcomes Beth L. Barnhard, Esq. Beth has joined the firm as Counsel in the Wills, Trusts and Estates Department. She is Certified to be an Elder Law Attorney (CELA) by the ABAaccredited National Elder Law Foundation.


View Announcement ›

SNYDER SARNO D'ANIELLO MACERI & DACOSTA

07/26/2021
NJLJ Web

SNYDER SARNO D'ANIELLO MACERI & DACOSTA is Proud to Announce the opening of New Morristown Office!


View Announcement ›