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Apr 8, 2010 · Worldwide unitary taxation came under assault in the 1980s and 1990s. In recent years, unitary combined reporting has seen a resurgence, as Vermont (2006), New York (2007), Michigan and Texas (2008), and Massachusetts, West Virginia, and Wisconsin (2009) have jumped on the bandwagon. Although "worldwide unitary combined reporting" was upheld ...
Feb 19, 2021 · The “unitary method” of taxation was developed to replace the “source method” strategy of taxation which would tax income based upon the geographic location where income was actually realized. California understood the source method of taxation failed to take into consideration the impact of a multi-state or multi-national corporation ...
Dec 8, 2010 · The Unitary Business Principle, Broadly One of the fundamental constitutional limitations on state corporate income taxation is that a state may not tax a corporation's income unless there is "some definite link, some minimum connection, between a state and the person, property or transaction it seeks to tax."
Nov 11, 2010 · Two tax concepts that states may employ to increase their tax revenue and that trap unwary foreign entities are (1) unitary combined reporting and (2) economic nexus. Unitary Combined Reporting Unitary combined reporting is a methodology for apportioning the business income of a corporation that is a member of a unitary business group.
For additional information about these items, contact Mr. Fairbanks at (202) 521-1503 or greg.fairbanks@gt.com. The use of mandatory unitary combined reporting has become increasingly popular among states in recent years, driven by state budgetary shortfalls and the perceived distortion of taxable income by multistate corporations filing ...
Combined reporting: a method of reporting/filing returns where all affiliates engaged in a unitary business must include their income, expenses, apportionment, etc. on a single report to calculate the group's tax liability. Consolidated return: a return where the parent corporation of an affiliated group includes the above items for itself and ...
On October 25, 2021, the California Franchise Tax Board (FTB) issued Legal Ruling 2021-01, Unity of Apportioning Pass-through Entities (Ruling), on how to apply unitary business principles to pass-through entities (such as partnerships, S corporations and limited liability companies treated as either) for the purpose of apportioning state taxes.
