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   Which states have mandatory unitary combined reporting?

   • Editor: Greg A. Fairbanks, J.D., LL.M. The use of mandatory unitary combined reporting has become increasingly popular among states in recent years. West Virginia, Massachusetts, and Wisconsin each unveiled combined reporting regimes for tax years beginning on or after January 1, 2009, and more states are likely to follow in the near future.

   The Recent Growth of Mandatory Unitary Combined Reporting

   www.thetaxadviser.com/issues/2010/feb/therecentgrowthofmandatoryunitarycombinedreporting.html

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   What is a unitary business?

   • While states initially applied the unitary concept to determine the share of income earned in the state by a single company, the principle was extended in later years to determine the share of income earned in the state by a multiple-entity unitary business.

   Decoding Combination: What Is a Unitary Business

   www.natlawreview.com/article/decoding-combination-what-unitary-business

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   Should a group of corporations be taxed as a unitary business?

   • Courts have consistently held that if a state is going to tax a group of entities as a single economic enterprise, the U.S. Constitution requires that members of the group of commonly controlled corporations constitute a unitary business.

   Worldwide combined reporting: An underutilized opportunity

   www.thetaxadviser.com/issues/2019/sep/worldwide-combined-reporting.html

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   Why is unitary combined reporting becoming more popular?

   • The increased acceptance of mandatory unitary combined reporting has been driven by state budgetary shortfalls and the perceived distortion of taxable income by multistate corporations filing separate company reports. A characteristic permeating each state’s reporting methodology is a broadly defined concept of the unitary business group.

   The Recent Growth of Mandatory Unitary Combined Reporting

   www.thetaxadviser.com/issues/2010/feb/therecentgrowthofmandatoryunitarycombinedreporting.html

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2. www.marcumllp.com › insights › state-corporateState Corporate Income Taxation: Trends in Combined Reporting

   www.marcumllp.com › insights › state-corporate

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   Nov 29, 2022 · A majority of states that impose a corporate income tax have adopted the use of mandatory worldwide, or water’s-edge, combined reporting methods for unitary businesses. At the same time, historically separate-filing states are seeking to adopt combined reporting tax regimes for corporate taxpayers.

3. www.thetaxadviser.com › issues › 2019Worldwide combined reporting: An underutilized opportunity

   www.thetaxadviser.com › issues › 2019

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   Under the worldwide combination method, a state imposes its tax on income apportioned to that state by the corporate taxpayer and all of its affiliates, domestic or foreign, that engage in a unitary business.

4. www.lorman.com › resources › spotlight-on-salt-theSpotlight on SALT: The Global Reach of State Unitary Tax ...

   www.lorman.com › resources › spotlight-on-salt-the

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   Tax treaties do not apply to U.S. States, with the general exception of tax treaty non-discrimination articles, and those potential situations where the actions of the State would prevent the U.S. from "speaking with one voice" when regulating foreign commerce.

5. www.cbpp.org › 28-states-plus-dc-require-combined28 States Plus D.C. Require Combined Reporting for the State ...

   www.cbpp.org › 28-states-plus-dc-require-combined

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   Advancing Racial Equity With State Tax Policy.

6. www.thetaxadviser.com › issues › 2010The Recent Growth of Mandatory Unitary Combined Reporting

   www.thetaxadviser.com › issues › 2010

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   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 separate company reports.

7. www.stateandlocaltax.com › in-the-news › waters-edgeWater’s-edge combined reports and 80/20 companies

   www.stateandlocaltax.com › in-the-news › waters-edge

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   Mar 27, 2023 · The unitary combined reporting method for state corporate income taxation has been adopted by an increasing number of states.

8. www.natlawreview.com › article › decodingDecoding Combination: What Is a Unitary Business

   www.natlawreview.com › article › decoding

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   Apr 14, 2015 · The unitary business principle finds its roots in 19th-century property taxation, when the U.S. Supreme Court first observed that an integrated business should be taxed as one unit...