Income Taxes: Definition of a Unitary Business (Portfolio 1110)

David-Fruchtman

David A. Fruchtman

Partner

Steptoe & Johnson LLP

Franklin Latcham

Deceased

Tax Management Portfolio Authors

At a glance

1110.01. INTRODUCTION
1110.02. OVERVIEW OF RULES DEFINING A UNITARY BUSINESS
1110.03. CONSTITUTIONAL LIMITATIONS ON THE UNITARY BUSINESS CONCEPT
1110.04. AMBIGUITIES CREATED BY CONTAINER
1110.05. ALLIED–SIGNAL CONFIRMS THE UNITARY PRINCIPLE
1110.06. STATE STANDARDS IN DEFINING A UNITARY BUSINESS
1110.07. COMBINED REPORTS AND OTHER MATTERS RELATED TO CORPORATE GROUPS
1110.08. FINAL COMMENT
1110.09. STATE-BY-STATE ANALYSIS OF THE UNITARY PRINCIPLE

Abstract

This Portfolio examines the unitary business concept and its importance to the application of formulary apportionment and to the resolution of the business vs. nonbusiness income issue.

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