State Tax

State Taxation of Corporate Income From Intangibles (Portfolio 1190)

  • This Portfolio analyzes the federal constitutional and state statutory rules governing state taxation of corporate income from intangibles. It attempts to untangle some of the more complex issues raised in this area and to provide a framework for sensibly resolving these issues in the future.

Description

The Bloomberg Tax Portfolio, State Taxation of Corporate Income From Intangibles Portfolio has two goals: to untangle some of the more complex issues raised in this area and to provide a framework for sensibly resolving these issues in the future.

The Portfolio also addresses other topics that are currently being debated by practitioners, administrators, and commentators. These topics include apportionability and fair apportionment, with particular emphasis on factor representation.

In attempting to provide a framework for the future, the Portfolio suggests various apportionment methods, with considerable attention to apportioning income on the basis of the intangible asset’s operational link to the corporation’s business.

Table of Contents

1190.01. INTRODUCTION
1190.02. STATE TAXATION OF CORPORATE INCOME: GENERAL PRINCIPLES
1190.03. STATE TAXATION OF CORPORATE INCOME FROM INTANGIBLES: GENERAL PRINCIPLES
1190.04. STATE TAXATION OF CORPORATE INCOME FROM INTANGIBLES: CURRENT CONTROVERSIES
1190.05. STATE TAXATION OF CORPORATE INCOME FROM INTANGIBLES: A FRAMEWORK FOR THE FUTURE
1190.06. CONCLUSION

Hellerstein-Walter
Walter Hellerstein
University of Georgia School of Law
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