Search results
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.
The unitary combined reporting deadline has passed. For more information see our Unitary Combined Report Reference Guide. Corporations subject to Virginia income tax may need to file a one-time report with Virginia Tax by July 1, 2021. This report will show the difference between the amount of tax the corporation would pay if it filed as part ...
McColgan, 8 where the California Supreme Court held that a unitary business exists “[i]f the operation of the portion of the business done within the state is dependent upon or contributes to the operation of the business done without the state”; and Mobil Oil Corp. v. Commissioner of Taxes of Vermont, 9 where the U.S. Supreme Court ...
Revision Information: This Technical Bulletin was revised on August 14, 2023, to include the broadened definition of unitary business in N.J.S.A. 54:10A-4(gg) of the Corporation Business Tax Act, which was codified in P.L. 2023, c. 96. P.L. 2018, c. 48, as amended by P.L. 2018, c. 131, requires mandatory unitary combined reporting for privilege ...
Original adopted in 1967 as part of the Multistate Tax Compact, revised by the MTC in 2014 and 2015. The original version of the Uniform Division of Income for Tax Purposes Act (UDITPA) was drafted by the Uniform Law Commission and included in Article IV of the Compact. In 2014 and 2015, the MTC recommended that states adopt uniform revisions ...
the operation of the business outside the state, the opera-tions are unitary; otherwise, if there is no such contribution or dependency, the business within the state may be consid-ered to be separate.16 4See State Railroad Tax Cases, 92 U.S. 575 (1875). 5166 U.S. 185 (1897). 6Id. at 222. 7254 U.S. 113 (1920). 8Id. at 120. 9 Id.at 121.
May 20, 2021 · May 20, 2021. California currently taxes the foreign income of a “unitary group” through worldwide combined reporting with a single sales factor for apportionment. Under this method, U.S. businesses and their foreign affiliates engaged in a single trade or business are treated as a “unitary group,” and the business income of the ...
