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An increasing number of states have enacted or proposed combined reporting requirements for related entities involved in a unitary business. As of Jan. 1, 2012, 24 states and the District of Columbia require combined reporting as part of their corporate income tax regimes.
- Background
- Unitary Business Concept in The Context of Unitary Combinedreporting
- Multistate Income Tax: Unitary Business by Blue J
- Appendix States Currently Requiring For Mandatory Combinedcombined Reporting
As the Supreme Court of the United States (the “U.S.Supreme Court” or the “Court”) pointed out inContainer Corp. of Am. v. Franchise Tax Bd., “theunitary business concept is not ... so to speak, unitary: there arevariations on the theme, and any number of them are logicallyconsistent with the underlying principles motivating theapproach.” While sta...
Currently, more than 30 states require mandatory unitarycombined reporting (“combined reporting”) for taxingincome purposes. The common theme of the different states'combined reporting regimes tries to capture the concept of unitarybusiness, at least for the enterprise unity, as a single economicenterprise that is made up of a group of business ent...
Blue J's Unitary Business predictor is specificallydesigned to predict whether a group of affiliated business entitiesconducts a unitary business within and without a state, based onyour fact pattern. Blue J's predictive module captures theunitariness of the unitary business concept across differentcombined states (with the exception of Arizona, wh...
References: 463 US 159, 167 (1983) 17 Cal. 2d 644 (1941), affd., 315 U.S. 501(1942) 445 U.S. 425, 439 (1980) See Container, 463 U.S. at 178-79. (the U.S.Supreme Court reiterated that the factors of profitability test arenecessary to finding unity; flow of value and not the flow of goodsis a necessary prerequisite to finding unity). The content of t...
All returns for members of a combined group (Form 355, 355S, or 63 FI) are produced at the separate company level. The unitary return (Form 355U) is produced in the consolidating unit with most of the information being saved off from separate company level input and brought into the consolidating unit. Q.
So, you could have multiple returns. Another way that you could be filing is a “water’s-edge filing.” That would be all the members of your group would file one unified return up to the boundaries of the water—the United States, essentially.
Dec 8, 2010 · Each year, many taxpayers file inaccurate corporate income tax returns in separate-reporting jurisdictions because they do not consider the unitary business principle applicable to those states. Although you may find this revelation shocking, the simple fact is that all states are unitary states.
A thorough discussion of the problems associated with MUCR can be found in the study prepared for COST by Ernst & Young LLP, “Understanding the Revenue and Competitive Effects of Mandatory Unitary Combined Reporting” (www.cost.org). 122 C Street, N.W., Suite 330 Washington, DC 20001-2109 Tel: 202/484-5222 Fax: 202/484-5229.
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Apr 17, 2024 · Unitary tax system is a taxation approach whereby the income of profits (and losses) of different branches of a corporation are calculated under one group. Unitary tax system is also called Formulary apportionment, under this system, all the profits and losses of different groups of the same corporation are allocated to a specific tax ...
