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   Should a state impose mandatory unitary combined reporting?

   • Mandatory Unitary Combined Reporting: States should not impose mandatory unitary combined reporting (MUCR) as provided in the COST Policy Statement opposing MUCR. MUCR may attribute more income to a state than is justified by the level of a corporation’s real economic activity in the state, and therefore combined reporting should be elective.

   State Corporate Income Tax Filing Methods Policy Position

   www.cost.org/globalassets/cost/state-tax-resources-pdf-pages/cost-policy-positions/state-tax-corporate-tax-filing-methods.pdf

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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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   When did unitary taxation come under attack?

   • 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.

   Spotlight on SALT: The Global Reach of State Unitary Tax

   www.lorman.com/resources/spotlight-on-salt-the-global-reach-of-state-unitary-tax-regimes-14882

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   Is a business within a state a unitary business?

   • Under this test, if the operation of a portion of the business done within the state depends on or contributes to the operation of the business outside the state, the operations are unitary; otherwise, if there is no such contributionor dependency, the business within the state may be considered to be separate.

   Decoding Combination: What Is a Unitary Business

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

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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.alvarezandmarsal.com › insights › news-flash-allNews Flash: All States Are Unitary States | Alvarez & Marsal ...

   www.alvarezandmarsal.com › insights › news-flash-all

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   Dec 8, 2010 · December 8, 2010. News Flash: All States Are Unitary States. 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.

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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   Apr 8, 2010 · 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.

5. 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.

6. 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 plays an important role not only as a criterion for combined reporting, but also as a touchstone for a state’s ability to tax extraterritorial values.

7. pro.bloombergtax.com › portfolio › income-taxesIncome Taxes: Consolidated Returns and Combined Reporting ...

   pro.bloombergtax.com › portfolio › income-taxes

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   Tax Management Portfolio Income Taxes: Consolidated Returns and Combined Reporting, No. 1130, compares state combined reports and state consolidated returns in detail and discusses the mechanics and implications of filing combined reports and the different types of state consolidated returns.

8. www.cost.org › globalassets › costState Corporate Income Tax Filing Methods Policy Position

   www.cost.org › globalassets › cost

   State Corporate Income Tax Filing Methods. Policy Position. Generally, states apportion the unitary business income of each separate taxable entity (separate reporting) or apportion the business income of the unitary group that includes one or more such taxable entities (combined reporting).