The Hawaii Supreme Court accepted applications for writs of certiorari in four consolidated corporate tax appeal cases on Jan. 5, 2026, setting the stage for a potentially significant review of state tax policy affecting research companies and tourism businesses.
The consolidated cases involve three companies challenging tax assessments by the State of Hawaii: PM & AM Research, Inc. appears in two separate appeals, while Big Island Science Center, LLC and Whale Watchers, LLC each filed individual tax appeals that have now been consolidated before the state's highest court.
According to court documents, all four cases originated from the Intermediate Court of Appeals and involve appeals from tax court decisions. The companies initially filed their tax appeals in trial court before pursuing appeals through Hawaii's court system.
PM & AM Research, Inc., which appears as petitioner in two of the four consolidated cases, represents a research company operating in Hawaii. The company's dual appeals suggest multiple tax assessment disputes with state authorities, though the specific nature of the tax disagreements remains unclear from available court filings.
Big Island Science Center, LLC represents another research-oriented entity challenging state tax determinations. The company's inclusion in the consolidated appeals indicates potential issues affecting science and research organizations operating in Hawaii's tax jurisdiction.
Whale Watchers, LLC, the third company involved in the consolidated appeals, appears to operate in Hawaii's tourism sector. The company's tax dispute adds a tourism industry dimension to what appears to be a broader examination of corporate tax policy in the state.
The Supreme Court of Hawaii issued its order accepting the applications for writs of certiorari under the leadership of Acting Chief Justice McKenna, joined by Justices Eddins, Ginoza, and Devens. The order represents the court's agreement to review the lower court decisions in these tax matters.
Consolidation of the four cases suggests the Hawaii Supreme Court identified common legal issues or questions of law that warrant unified review. Tax appeals reaching the state supreme court level typically involve significant legal questions that could affect broader categories of taxpayers or establish important precedent for future tax disputes.
The cases progressed through Hawaii's three-tier court system, beginning in trial court where initial tax appeal determinations were made. The companies then appealed to the Intermediate Court of Appeals, which issued decisions that are now subject to supreme court review.
Corporate tax appeals in Hawaii often involve disputes over assessment methodologies, tax classification issues, or challenges to specific tax obligations imposed by state authorities. The involvement of research companies and tourism businesses suggests potential questions about how different types of commercial activities are taxed under Hawaiian law.
For PM & AM Research, Inc., the dual appeals indicate the company faced multiple tax assessment challenges, possibly spanning different tax years or involving different aspects of its research operations. Research companies often face complex tax issues related to intellectual property, equipment depreciation, or classification of research activities.
Big Island Science Center's involvement adds another research entity to the consolidated appeals, suggesting potential systemic issues affecting how science and research organizations are taxed in Hawaii. Such organizations often operate with unique business models that may present novel tax classification questions.
Whale Watchers, LLC represents Hawaii's important tourism sector, which faces specific tax considerations related to excise taxes, transient accommodations taxes, and other tourism-related levies. The company's inclusion broadens the potential impact of the supreme court's eventual rulings.
The timing of the court's acceptance of these cases, filed at the beginning of 2026, positions them for potential resolution during the court's current term. Tax cases often receive expedited consideration due to their financial implications for both taxpayers and state revenue.
State tax authorities will defend their assessment decisions before the supreme court, likely arguing that existing tax law and regulations support their determinations in each case. The state's position will need to address whatever common legal issues prompted the court to consolidate these diverse tax appeals.
The consolidated review could establish important precedent affecting how Hawaii taxes research companies, tourism businesses, and potentially other commercial entities. Supreme court decisions in tax matters often provide guidance that influences future assessment practices and dispute resolution.
Businesses operating in Hawaii will likely monitor these consolidated cases for potential implications affecting their own tax obligations. The outcome could clarify important aspects of state tax law or modify how certain business activities are assessed for tax purposes.
The cases represent a significant moment for Hawaii tax policy, bringing together disputes from research and tourism sectors that form important components of the state's economy. The supreme court's eventual decisions could have lasting effects on how these industries interact with state tax authorities.