State Tax

Limitations on States’ Jurisdiction to Impose Net Income Based Taxes (Portfolio 1410)

  • This Portfolio examines the identification of those jurisdictions in which a corporation’s activities may be subject to a tax.

Description

The Bloomberg Tax Portfolio, Limitations on States’ Jurisdiction to Impose Net Income Based Taxes Portfolio is designed to guide practitioners in their quest to solve the enigma of state taxing jurisdiction.

In addition to an analysis of the states’ interpretations of Public Law 86–272, the Portfolio discusses court decisions under both the Commerce and Due Process Clauses as they pertain to state taxing jurisdiction.

Table of Contents

1410.01. Introduction
1410.02. Constitutional Limitations On State Taxing Authority
1410.03. Contacts Establishing a Sufficient Basis for Imposition of Net Income-Based Taxes
1410.05. Practices Of the Mutistate tax Commission Under Pub. L. No. 86-272
1410.06. Correlative Use of Pub. L. NO. 86-272 To Deny Apportionment
1410.07. Impact of Public Law 86-272 On the Receipts Factor Of The Apportionment Formula
1410.08. Applicability of Public Law 86-272 To Members of Unitary Business Groups
1410.09. Applicability of Public Law 86-272 To None U.S. Corporations
1410.10. Intangible Holding Companies
1410.11. Planning Opportunities
1410.12. Conclusion

marcus-fred-2015
Fred Marcus
Horwood Marcus & Berk Chartered
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