Fair apportionment is a constitutional requirement. According to Complete Auto Transit Inc. v. Brady, 430 U.S. 274 (1977), to be fairly apportioned, a state tax on corporate income must be limited to ...
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in ...
Why only seek an alternative formula when you can win under the normal formula? A corporate taxpayer won under a special-industry normal apportionment formula, and it won the right to use an ...
California legislators released bill language addressing Governor Gavin Newsom’s “May Revise” to the state budget that includes the Governor’s so-called “apportionment fix.” If enacted, Assembly Bill ...
We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...
The share of corporate profits in the U.S. collected by state governments via the corporate income tax has fallen sharply in the past quarter century. Some commentators have even referred to this as ...
We collaborate with the world's leading lawyers to deliver news tailored for you. Sign Up for any (or all) of our 25+ Newsletters. Some states have laws and ethical rules regarding solicitation and ...
Technology is enabling businesses to perform tasks more efficiently and provide services to customers in ways they never thought possible. Yet these novel processes and products present considerable ...
Applying the time-based apportionment formulas to determine capital gains can have absurd results and seriously prejudice taxpayers. The attempt at simplicity has resulted in a lack of equity in the ...
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