State Tax

Income Taxes: Special Problems in Formulary Apportionment (Portfolio 1180)

  • This Portfolio focuses on advanced apportionment principles and special problems.


The Tax Management Portfolio, Income Taxes: Special Problems in Formulary Apportionment includes a review of constitutional principles and focuses on distortion in the apportionment of income. It is not intended to be an exhaustive review of basic state apportionment principles. Rather, references are made to the laws of certain jurisdictions for illustrative purposes. As with all state taxation, relevant statutes, regulations, administrative decisions and case law should be consulted for specific guidance.

Table of Contents

1180.01. Introduction & Overview
1180.02. Purpose And Common Methods Of Apportionment
1180.03. Constitutional Requirement
1180.04. Revising the Apportionment Formula
1180.05. Measuring and Proving Distortion
1180.06. Combined & Consolidated Reporting
1180.07. Factors That Do Not Fairly Represent Business Activity
1180.08. Attributional Apportionment

Bobby Burgner
Retired Senior Tax Counsel, Global Indirect Tax Leader
GE Corporate Tax
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