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  2. The resulting State tax filing and income apportionment could trip the 80/20 rule for unitary States where U.S. subsidiaries operate. Second, more unitary combined reporting States are adopting economic presence "nexus" to target foreign corporations.

  3. DEFINING A UNITARY BUSINESS: AN ECONOMISTS VIEW. Abstract. The definition of a unitary business has figured prominently in several recent decisions of the U.S. Supreme Court on the. constitutionality of state corporate income taxes. This paper. employs economic analysis to frame a three part test of whether a. unitary business exists.

    • Charles E McLure, Charles E McLure
    • 1983
  4. Mar 1, 2001 · The finding that tax rate cuts are ineffective in nonunitary states implies that these states may be more successful in attracting investment by changes affecting apportionment factors (tax credits for new capital, or new jobs) or by use of nontax incentives. This content is only available via PDF. American Accounting Association.

    • Country-By-Country Reports of Us Multinationals
    • The Opportunity to Create A Unitary Taxation Regime
    • Conclusion

    In the US, the CbCR is mandatory for multinational enterprises with more than $850 million of revenue since 2016. The report must include sales, assets, taxes paid and other indicators of economic activity on a country-by-country basis. The data are communicated to the Internal Revenue Service using a specific form. The information is subsequently ...

    Table 1 exhibits the outcome of the Commission’s CCCTB proposal applied to the IRS database. The apportionment formula is applied to the 1,205 US multinationals operating in EU countries. In the first column, we see the pre-tax profits reported by multinational companies in each of the member states (including the United Kingdom). Estonia and Malta...

    Current corporate tax systems and institutions for international cooperation in tax matters were created in the early 20th century. Since then, the process of economic globalisation has completely changed the production and marketing chains. The companies have gained scale and internationalised their business. Taking advantage of digitalisation, co...

    • Miguel Viegas, António Dias
    • 2021
  5. Issue Date May 1983. The definition of a unitary business has figured prominently in several recent decisions of the U.S. Supreme Court on the constitutionality of state corporate income taxes. This paper employs economic analysis to frame a three part test of whether a unitary business exists.

    • Charles E McLure, Charles E McLure
    • 1983
  6. Apr 14, 2015 · The unitary business principle originated in the United States in the 19th century with state property taxes and transcontinental railroad and express companies. The issue in those early cases was ...

  7. Jan 12, 2016 · Research finds that higher state taxes are generally associated with lower economic performance. There is somewhat weaker evidence that state and local taxes can significantly reduce income growth within a state, particularly when the revenues raised are devoted to transfer payments.

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