The Matter of Walt Disney Company v. Tax Appeals Tribunal of the State of New York , the Matter of International…

Summary

The court affirmed judgments denying Disney and IBM deductions for royalty payments received from foreign affiliates because the deduction was available only when the related payor was subject to New York's royalty-payment add-back requirement. It held that this interpretation followed the statute's plain meaning and legislative purpose and did not facially discriminate against interstate or foreign commerce or fail the internal consistency test. The court therefore affirmed both judgments with costs.