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Google Keyword Rankings for : unitary business relationship
1
TB-93 The Unitary Business Principle and Combined Returns
https://www.state.nj.us/treasury/taxation/pdf/pubs/tb/tb93.pdf
'Unitary business' means a single economic enterprise that is made up either of separate parts of a single business entity or of a group of ...
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https://www.state.nj.us/treasury/taxation/pdf/pubs/tb/tb93.pdf
'Unitary business' means a single economic enterprise that is made up either of separate parts of a single business entity or of a group of ...
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2
Decoding Combination: What Is a Unitary Business
https://www.natlawreview.com/article/decoding-combination-what-unitary-business
The unitary business principle finds its roots in 19th-century property taxation, when the U.S. Supreme Court first observed that an integrated ...
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https://www.natlawreview.com/article/decoding-combination-what-unitary-business
The unitary business principle finds its roots in 19th-century property taxation, when the U.S. Supreme Court first observed that an integrated ...
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3
Unitary Business Principle Clarified - Journal of Accountancy
https://www.journalofaccountancy.com/issues/2008/jul/unitarybusinessprincipleclarified.html
The concept of operational function simply recognizes that an asset can be part of a taxpayer's unitary business even if what we may term a ' ...
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https://www.journalofaccountancy.com/issues/2008/jul/unitarybusinessprincipleclarified.html
The concept of operational function simply recognizes that an asset can be part of a taxpayer's unitary business even if what we may term a ' ...
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4
Unitary Concept - The CPA Journal Archive
http://archives.cpajournal.com/1998/0398/Features/F460398.htm
The unitary business concept requires the decomposition of taxable income into business and nonbusiness income on a consolidated basis. In turn, the business ...
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http://archives.cpajournal.com/1998/0398/Features/F460398.htm
The unitary business concept requires the decomposition of taxable income into business and nonbusiness income on a consolidated basis. In turn, the business ...
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5
Press Room: Tax Release - Andersen
https://andersen.com/pressroom/selling-a-business-unit-understand-the-unitary-business-doctrine-to-anticip
The unitary business principle is premised on the idea that certain integrated businesses should be taxed as a single unit. This principle ...
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https://andersen.com/pressroom/selling-a-business-unit-understand-the-unitary-business-doctrine-to-anticip
The unitary business principle is premised on the idea that certain integrated businesses should be taxed as a single unit. This principle ...
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6
Minn. R. 8019.0100 - DEFINITION OF UNITARY BUSINESS
https://www.law.cornell.edu/regulations/minnesota/Minn-R-8019-0100
Business activities or operations carried on by more than one corporation, related through common ownership, are generally unitary when the activities of the ...
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https://www.law.cornell.edu/regulations/minnesota/Minn-R-8019-0100
Business activities or operations carried on by more than one corporation, related through common ownership, are generally unitary when the activities of the ...
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7
The Scoop on the Unitary Business Principle: How Blue Bell's ...
https://www.americanbar.org/groups/taxation/publications/tax_lawyer_home/11sum/ttl-sum11-harding/
So long as a state establishes that a corporation's in-state and out-of-state activities are unitary, the principle permits the state to tax an ...
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https://www.americanbar.org/groups/taxation/publications/tax_lawyer_home/11sum/ttl-sum11-harding/
So long as a state establishes that a corporation's in-state and out-of-state activities are unitary, the principle permits the state to tax an ...
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8
2021 Schedule UB Instructions - Illinois.gov
https://www2.illinois.gov/rev/forms/incometax/Documents/currentyear/business/miscellaneous/schedule-ub-instr.pdf
for Unitary Business Group, is to enable a unitary business group ... incurred in connection with the acquisition and holding of interests in.
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https://www2.illinois.gov/rev/forms/incometax/Documents/currentyear/business/miscellaneous/schedule-ub-instr.pdf
for Unitary Business Group, is to enable a unitary business group ... incurred in connection with the acquisition and holding of interests in.
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9
VAS Holdings and the Battle Over Taxing Non-Unitary Capital ...
https://news.bloombergtax.com/tax-insights-and-commentary/vas-holdings-and-the-battle-over-taxing-non-unitary-capital-gains
Is the unitary business principle the sole test for determining whether a state can tax an apportioned share of a non-domiciliary's capital ...
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https://news.bloombergtax.com/tax-insights-and-commentary/vas-holdings-and-the-battle-over-taxing-non-unitary-capital-gains
Is the unitary business principle the sole test for determining whether a state can tax an apportioned share of a non-domiciliary's capital ...
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10
The Unitary Business Principle - Module 7 - Coursera
https://www.coursera.org/lecture/multistate-taxation/the-unitary-business-principle-mP63D
Specifically, the due process clause requires both a definite link or some minimum connection between a state and the person property or ...
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https://www.coursera.org/lecture/multistate-taxation/the-unitary-business-principle-mP63D
Specifically, the due process clause requires both a definite link or some minimum connection between a state and the person property or ...
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11
Defining a Unitary Business: An Economist's View, 30 Years ...
https://www.mtc.gov/getattachment/Events-Training/2015/48th-Annual-Conference-Committee-Meetings/McLure-Slides.pdf.aspx
unitary business principle''. – Exxon, ASARCO, Woolworth, Container, Allied-. Signal, and MeadWestvaco also hinged on existence of a unitary relationship ...
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https://www.mtc.gov/getattachment/Events-Training/2015/48th-Annual-Conference-Committee-Meetings/McLure-Slides.pdf.aspx
unitary business principle''. – Exxon, ASARCO, Woolworth, Container, Allied-. Signal, and MeadWestvaco also hinged on existence of a unitary relationship ...
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12
Legal Ruling 2021-01 - Franchise Tax Board
https://www.ftb.ca.gov/tax-pros/law/legal-rulings/2021-01.pdf
create a unitary business relationship between the parent and holding company. This investment construction of the California tax laws 'is ...
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https://www.ftb.ca.gov/tax-pros/law/legal-rulings/2021-01.pdf
create a unitary business relationship between the parent and holding company. This investment construction of the California tax laws 'is ...
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13
SALT Glossary of Terms - Council On State Taxation
https://www.cost.org/state-tax-resources/salt-glossary-of-terms/
Unitary – Judicially developed Constitutional concept whereby separate legal business entities are treated for tax purposes as a single business unit based on ...
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https://www.cost.org/state-tax-resources/salt-glossary-of-terms/
Unitary – Judicially developed Constitutional concept whereby separate legal business entities are treated for tax purposes as a single business unit based on ...
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14
UDITPA and Combined Unitary Reporting
https://revenue.louisiana.gov/Miscellaneous/Combined%20Reporting_2.pdf
affiliate's income that is derived from a unitary business con- ... business of the corpo- tation and there is a direct economic relationship between the.
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https://revenue.louisiana.gov/Miscellaneous/Combined%20Reporting_2.pdf
affiliate's income that is derived from a unitary business con- ... business of the corpo- tation and there is a direct economic relationship between the.
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15
Rule - 150-317-0510 Unitary Business - OregonLaws
https://oregon.public.law/rules/oar_150-317-0510
(6) Unitary Business Unaffected by Formal Business Organization. A unitary business may exist within a single business entity or among a commonly controlled ...
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https://oregon.public.law/rules/oar_150-317-0510
(6) Unitary Business Unaffected by Formal Business Organization. A unitary business may exist within a single business entity or among a commonly controlled ...
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16
Section 280-RICR-20-25-10.8 - Unitary Business - Casetext
https://casetext.com/regulation/rhode-island-administrative-code/title-280-department-of-revenue/chapter-20-division-of-taxation/subchapter-25-business-corporation-tax/part-10-combined-reporting-280-ricr-20-25-10/section-280-ricr-20-25-108-unitary-business-further-defined
The Court has variously expressed the constitutional test, holding that a finding of unitary relationship requires "contribution or dependency" between ...
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https://casetext.com/regulation/rhode-island-administrative-code/title-280-department-of-revenue/chapter-20-division-of-taxation/subchapter-25-business-corporation-tax/part-10-combined-reporting-280-ricr-20-25-10/section-280-ricr-20-25-108-unitary-business-further-defined
The Court has variously expressed the constitutional test, holding that a finding of unitary relationship requires "contribution or dependency" between ...
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17
Rule 3.590 - Texas Administrative Code
https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=34&pt=1&ch=3&rl=590
When a taxable entity forms another taxable entity, a unitary relationship exists as of the date of formation unless the business is not unitary on a longer ...
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https://texreg.sos.state.tx.us/public/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=34&pt=1&ch=3&rl=590
When a taxable entity forms another taxable entity, a unitary relationship exists as of the date of formation unless the business is not unitary on a longer ...
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18
A Question of Fact: Illinois Tax Tribunal Denies Summary ...
https://www.saltsavvy.com/2021/08/09/a-question-of-fact-illinois-tax-tribunal-denies-summary-judgment-motion-in-unitary-business-case/
Under the IITA, a “unitary business group” is defined as “a group of persons related through common ownership whose business activities are ...
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https://www.saltsavvy.com/2021/08/09/a-question-of-fact-illinois-tax-tribunal-denies-summary-judgment-motion-in-unitary-business-case/
Under the IITA, a “unitary business group” is defined as “a group of persons related through common ownership whose business activities are ...
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19
830 CMR 63.32B.2: Combined Reporting - Mass.gov
https://www.mass.gov/regulations/830-CMR-6332b2-combined-reporting
An intermediate passive holding company shall be deemed to be engaged in a unitary business with the parent and subsidiary or subsidiaries and includable in a ...
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https://www.mass.gov/regulations/830-CMR-6332b2-combined-reporting
An intermediate passive holding company shall be deemed to be engaged in a unitary business with the parent and subsidiary or subsidiaries and includable in a ...
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20
unitary | SALT Shaker
https://www.stateandlocaltax.com/tag/unitary/
... was a lack of a unitary business relationship between an out-of-state holding ... can require interstate unitary businesses to use combined reporting, ...
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https://www.stateandlocaltax.com/tag/unitary/
... was a lack of a unitary business relationship between an out-of-state holding ... can require interstate unitary businesses to use combined reporting, ...
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21
Requirements for Unitary Groups - Oregon Secretary of State
https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=271089
(6) Unitary Business Unaffected by Formal Business Organization. A unitary business may exist within a single entity or among a commonly owned group of entities ...
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https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=271089
(6) Unitary Business Unaffected by Formal Business Organization. A unitary business may exist within a single entity or among a commonly owned group of entities ...
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22
Redefining Taxation of International Entities: The Unitary ...
https://digitalcommons.du.edu/cgi/viewcontent.cgi?article=2291&context=djilp
that a unitary business relationship between ASARCO and the dividend paying companies is a necessary prerequisite to its taxation of the income.
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https://digitalcommons.du.edu/cgi/viewcontent.cgi?article=2291&context=djilp
that a unitary business relationship between ASARCO and the dividend paying companies is a necessary prerequisite to its taxation of the income.
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23
Affiliated Corporations | Department of Revenue - Colorado tax
https://tax.colorado.gov/affiliated-corporations
However, only those members doing business in Colorado, as defined in Regulation ... business relationship tests for this year and the preceding two years.
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https://tax.colorado.gov/affiliated-corporations
However, only those members doing business in Colorado, as defined in Regulation ... business relationship tests for this year and the preceding two years.
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24
New York-combined reporting permitted under unitary ...
https://www2.deloitte.com/us/en/pages/tax/articles/multistate-tax-alert-new-york-combined-reporting-permitted-under-unitary-business-analysis.html
Applying these unitary business principles, the Tribunal concluded that many of SunGard's entities were engaged in the same or related lines of business.13 More ...
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https://www2.deloitte.com/us/en/pages/tax/articles/multistate-tax-alert-new-york-combined-reporting-permitted-under-unitary-business-analysis.html
Applying these unitary business principles, the Tribunal concluded that many of SunGard's entities were engaged in the same or related lines of business.13 More ...
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25
SN 93-26 - CT.gov
https://portal.ct.gov/DRS/Publications/Special-Notices/1993/SN-93-26
Because the parties stipulated that Bendix and ASARCO were entirely unrelated business enterprises, the Court found that no unitary business relationship ...
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https://portal.ct.gov/DRS/Publications/Special-Notices/1993/SN-93-26
Because the parties stipulated that Bendix and ASARCO were entirely unrelated business enterprises, the Court found that no unitary business relationship ...
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26
Revenue Notice #08-03: Corporate Franchise Tax
https://www.revenue.state.mn.us/revenue-notice/08-03-corporate-franchise-tax-treatment-partnership-income-corporate-partners
When a corporation and a partnership are engaged in a unitary business, the corporation must include its partnership income in its apportionable business income ...
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https://www.revenue.state.mn.us/revenue-notice/08-03-corporate-franchise-tax-treatment-partnership-income-corporate-partners
When a corporation and a partnership are engaged in a unitary business, the corporation must include its partnership income in its apportionable business income ...
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27
The Unitary Concept in State Income Taxation of Multistate ...
https://www.jstor.org/stable/27890815
taxpayer is conducting such a unitary business, what income of ... and their value as separate cars did not bear a direct relation to the valua.
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https://www.jstor.org/stable/27890815
taxpayer is conducting such a unitary business, what income of ... and their value as separate cars did not bear a direct relation to the valua.
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28
Allied-Signal, Inc. v. Director, Div. of Taxation :: 504 U.S. 768 ...
https://supreme.justia.com/cases/federal/us/504/768/
The unitary business rule is a recognition of the States' wide authority to devise formulae for an accurate assessment of a corporation's intrastate value or ...
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https://supreme.justia.com/cases/federal/us/504/768/
The unitary business rule is a recognition of the States' wide authority to devise formulae for an accurate assessment of a corporation's intrastate value or ...
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29
Combined Reporting - Idaho State Tax Commission
https://tax.idaho.gov/i-2039.cfm
The unitary business principle was first developed in the 1870s when local governments were imposing a property tax on railroads operating ...
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https://tax.idaho.gov/i-2039.cfm
The unitary business principle was first developed in the 1870s when local governments were imposing a property tax on railroads operating ...
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30
defining a unitary business: an economist's view
https://www.nber.org/system/files/working_papers/w1125/w1125.pdf
in a unitary business and that combination is required if firms are not to ... include those based on the technical relationship between diameter and.
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https://www.nber.org/system/files/working_papers/w1125/w1125.pdf
in a unitary business and that combination is required if firms are not to ... include those based on the technical relationship between diameter and.
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31
Reg. § 1.5862(d) Unitary Combined Reporting
https://tax.vermont.gov/sites/tax/files/documents/15862d.pdf
income tax of unitary businesses and for filing the group return required under 32 ... finding of unitary relationship requires “contribution or dependency” ...
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https://tax.vermont.gov/sites/tax/files/documents/15862d.pdf
income tax of unitary businesses and for filing the group return required under 32 ... finding of unitary relationship requires “contribution or dependency” ...
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32
Section 9-158. COMBINED REPORTING: DETERMINATION ...
http://dcrules.elaws.us/dcmr/9-158
Business activities which might otherwise be considered as part of more than one (1) unitary business may constitute one (1) unitary business when there is a ...
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http://dcrules.elaws.us/dcmr/9-158
Business activities which might otherwise be considered as part of more than one (1) unitary business may constitute one (1) unitary business when there is a ...
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33
The Unitary Concept in the Allocation of Income
https://repository.uchastings.edu/cgi/viewcontent.cgi?article=1635&context=hastings_law_journal
the fluctuation of values of property used in a unitary business. ... lies solely in the difference in the relationship of various businesses to.
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https://repository.uchastings.edu/cgi/viewcontent.cgi?article=1635&context=hastings_law_journal
the fluctuation of values of property used in a unitary business. ... lies solely in the difference in the relationship of various businesses to.
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34
California Franchise Tax Board issues legal ruling on unitary ...
https://taxnews.ey.com/news/2021-2017
In Legal Rulings 1995-7 and 1995-8, the FTB determined that holding companies will usually be engaged in a unitary business with the operating ...
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https://taxnews.ey.com/news/2021-2017
In Legal Rulings 1995-7 and 1995-8, the FTB determined that holding companies will usually be engaged in a unitary business with the operating ...
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35
NJ Releases a Technical Tax Bulletin to Explain Unitary ...
https://www.citrincooperman.com/infocus/nj-releases-a-technical-tax-bulletin-to-explain-unitary-business-principle
TB-93 defines a “unitary business” as a single economic enterprise, which, despite different legal entities or active components, shares common ownership and a ...
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https://www.citrincooperman.com/infocus/nj-releases-a-technical-tax-bulletin-to-explain-unitary-business-principle
TB-93 defines a “unitary business” as a single economic enterprise, which, despite different legal entities or active components, shares common ownership and a ...
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36
United States: A question of fact - Illinois tax tribunal denies ...
https://insightplus.bakermckenzie.com/bm/tax/united-states-a-question-of-fact-illinois-tax-tribunal-denies-summary-judgment-motion-in-unitary-business-case
The Tribunal's decision highlights the general notion that the existence of a unitary relationship between two business enterprises, or between a business ...
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https://insightplus.bakermckenzie.com/bm/tax/united-states-a-question-of-fact-illinois-tax-tribunal-denies-summary-judgment-motion-in-unitary-business-case
The Tribunal's decision highlights the general notion that the existence of a unitary relationship between two business enterprises, or between a business ...
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37
TAX CODE CHAPTER 171. FRANCHISE TAX - Texas Statutes
https://statutes.capitol.texas.gov/Docs/TX/htm/TX.171.htm
In determining whether a unitary business exists, the comptroller shall ... does not apply to any change in the tax imposed by this chapter in relation to:.
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https://statutes.capitol.texas.gov/Docs/TX/htm/TX.171.htm
In determining whether a unitary business exists, the comptroller shall ... does not apply to any change in the tax imposed by this chapter in relation to:.
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38
New York Combined Return Rules Begin to Gain Clarity
https://www.pkfod.com/wp-content/uploads/2018/11/Update-on-NYS-Combined-Return-Rules.pdf
mandatory unitary combined group reporting. ... Further, in the following situations, a unitary business relationship is presumed when corporations:.
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https://www.pkfod.com/wp-content/uploads/2018/11/Update-on-NYS-Combined-Return-Rules.pdf
mandatory unitary combined group reporting. ... Further, in the following situations, a unitary business relationship is presumed when corporations:.
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39
New Yorks's Proposed Corporate Tax Reform Regulations
https://tax.thomsonreuters.com/news/new-yorkss-proposed-corporate-tax-reform-regulations-selected-topics-part-1-separate-accounting-elections/
In addition, a unitary business relationship may exist when the entities are engaged in related lines or businesses.
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https://tax.thomsonreuters.com/news/new-yorkss-proposed-corporate-tax-reform-regulations-selected-topics-part-1-separate-accounting-elections/
In addition, a unitary business relationship may exist when the entities are engaged in related lines or businesses.
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40
Unitary Combined Report Reference Guide - Virginia Tax
https://www.tax.virginia.gov/sites/default/files/inline-files/Unitary-Combined-Report-Reference-Guide.pdf
For purposes of this reporting requirement, a “unitary business” is ... business relationship exist with at least one corporation that has ...
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https://www.tax.virginia.gov/sites/default/files/inline-files/Unitary-Combined-Report-Reference-Guide.pdf
For purposes of this reporting requirement, a “unitary business” is ... business relationship exist with at least one corporation that has ...
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41
Income Apportionment and Allocation after Mead
https://www.thetaxadviser.com/issues/2010/sep/salt-sept10-im.html
Under the unitary business principle, if at least one member of a corporate group is subject to a state's taxing jurisdiction, the entire income ...
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https://www.thetaxadviser.com/issues/2010/sep/salt-sept10-im.html
Under the unitary business principle, if at least one member of a corporate group is subject to a state's taxing jurisdiction, the entire income ...
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42
Arizona Corporate Tax Ruling CTR 00-2
https://azdor.gov/sites/default/files/RULINGS_CORP_2000_ctr00-2.pdf
part of the unitary business is conducted in Arizona. ... including the business relationship of the corporations sought to be combined,.
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https://azdor.gov/sites/default/files/RULINGS_CORP_2000_ctr00-2.pdf
part of the unitary business is conducted in Arizona. ... including the business relationship of the corporations sought to be combined,.
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43
combined_reporting_to_date.pdf
https://otr.cfo.dc.gov/sites/default/files/dc/sites/otr/publication/attachments/combined_reporting_to_date.pdf
net income derived from the unitary business as its apportioned share of the income ... periods thereafter, a presumption of a unitary relationship exists.
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https://otr.cfo.dc.gov/sites/default/files/dc/sites/otr/publication/attachments/combined_reporting_to_date.pdf
net income derived from the unitary business as its apportioned share of the income ... periods thereafter, a presumption of a unitary relationship exists.
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44
Virginia unitary businesses must submit informational report ...
https://rsmus.com/insights/tax-alerts/2021/virginia-unitary-businesses-must-submit-informational-report-by.html
Members of a unitary combined group must also exclude the income and apportionment factors of any corporation incorporated in a foreign ...
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https://rsmus.com/insights/tax-alerts/2021/virginia-unitary-businesses-must-submit-informational-report-by.html
Members of a unitary combined group must also exclude the income and apportionment factors of any corporation incorporated in a foreign ...
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45
TEXAS SUPREME COURT DECISION AND ...
https://www.bdo.com/getattachment/9a02014c-6d2c-4519-86be-43060d9344b5/attachment.aspx?SALT-Alert_TX-franchise-tax-decisions_JN.pdf
“unitary business” group, and the other addresses the inclusion of captive ... In determining whether a unitary relationship exists, 34 Tex.
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https://www.bdo.com/getattachment/9a02014c-6d2c-4519-86be-43060d9344b5/attachment.aspx?SALT-Alert_TX-franchise-tax-decisions_JN.pdf
“unitary business” group, and the other addresses the inclusion of captive ... In determining whether a unitary relationship exists, 34 Tex.
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46
Title 103 Chapter 16 Regulation 400 • Kentucky Administrative ...
https://apps.legislature.ky.gov/law/kar/titles/103/016/400/
same type of business. Business activities that are in the same general line of business shall generally constitute a single unitary business, as, for example, ...
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https://apps.legislature.ky.gov/law/kar/titles/103/016/400/
same type of business. Business activities that are in the same general line of business shall generally constitute a single unitary business, as, for example, ...
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47
Corporation Income Tax Regulations
https://www.dfa.arkansas.gov/images/uploads/revenuePolicyLegalOffice/it1998_1.pdf
These factors help determine the existence of a unitary relationship for classifying income as business income. However,. Arkansas will not accept returns filed ...
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https://www.dfa.arkansas.gov/images/uploads/revenuePolicyLegalOffice/it1998_1.pdf
These factors help determine the existence of a unitary relationship for classifying income as business income. However,. Arkansas will not accept returns filed ...
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48
Title 12 - Missouri Department of Revenue
https://dor.mo.gov/resources/official-final-rules/documents/12_CSR_10-2_076.pdf
(B) The taxpayer derives income from a part of its unitary business in another state, ... no relation to the taxpayer's business activity within that state, ...
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https://dor.mo.gov/resources/official-final-rules/documents/12_CSR_10-2_076.pdf
(B) The taxpayer derives income from a part of its unitary business in another state, ... no relation to the taxpayer's business activity within that state, ...
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49
California and Unitary Taxation: The Continuing Saga
https://journals.iupui.edu/index.php/iiclr/article/download/17476/17591
unitary business or one taxpayer.5 What is meant by "related" has ... The case turned largely on the relationship between the California.
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https://journals.iupui.edu/index.php/iiclr/article/download/17476/17591
unitary business or one taxpayer.5 What is meant by "related" has ... The case turned largely on the relationship between the California.
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50
Memorandum - Montana State Legislature
https://leg.mt.gov/content/Committees/Interim/2019-2020/Revenue/Meetings/July-2020/DOR-tax-haven-update-2020.pdf
(a Montana taxpayer) is in a unitary business relationship with DEG Corp. (a Delaware corporation) and XYZ Corp. (a Canada corporation), then ABC will file a ...
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https://leg.mt.gov/content/Committees/Interim/2019-2020/Revenue/Meetings/July-2020/DOR-tax-haven-update-2020.pdf
(a Montana taxpayer) is in a unitary business relationship with DEG Corp. (a Delaware corporation) and XYZ Corp. (a Canada corporation), then ABC will file a ...
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51
Unitary Income In Mass., Guidance In Md.: SALT In Review
https://www.law360.com/tax-authority/articles/1491447/unitary-income-in-mass-guidance-in-md-salt-in-review
If you can apportion such income, the SALT world will be turned upside down. It is the unitary relationship that provides the connection to the ...
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https://www.law360.com/tax-authority/articles/1491447/unitary-income-in-mass-guidance-in-md-salt-in-review
If you can apportion such income, the SALT world will be turned upside down. It is the unitary relationship that provides the connection to the ...
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52
77-2734.04 - Nebraska Legislature
https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.04
(27) Unitary business means a business that is conducted as a single economic unit by one or more corporations with common ownership and shall include all ...
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https://nebraskalegislature.gov/laws/statutes.php?statute=77-2734.04
(27) Unitary business means a business that is conducted as a single economic unit by one or more corporations with common ownership and shall include all ...
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53
Corporate Tax Reform FAQs - Tax.NY.gov
https://www.tax.ny.gov/bus/ct/corp_tax_reform_faqs.htm
... ownership requirements of Tax Law § 210-C(2)(a) without regard to also meeting the unitary business requirement for combined reporting.
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https://www.tax.ny.gov/bus/ct/corp_tax_reform_faqs.htm
... ownership requirements of Tax Law § 210-C(2)(a) without regard to also meeting the unitary business requirement for combined reporting.
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54
Tennessee and New Jersey Unitary Business Case Studies
https://www.bakerdonelson.com/Slicing-Shadows-Whipsaws-and-Flow-Through-Entities-Tennessee-and-New-Jersey-Unitary-Business-Case-Studies-07-26-2012
The unitary business principle is central to the constitutional limits on state taxation of corporate income . Before a state can require a non- ...
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https://www.bakerdonelson.com/Slicing-Shadows-Whipsaws-and-Flow-Through-Entities-Tennessee-and-New-Jersey-Unitary-Business-Case-Studies-07-26-2012
The unitary business principle is central to the constitutional limits on state taxation of corporate income . Before a state can require a non- ...
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55
General Law - Part I, Title IX, Chapter 63, Section 32B
https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section32B
A group of corporations under common ownership may be engaged in 1 or more unitary businesses. (3) Any business conducted by a partnership shall be treated as ...
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https://malegislature.gov/Laws/GeneralLaws/PartI/TitleIX/Chapter63/Section32B
A group of corporations under common ownership may be engaged in 1 or more unitary businesses. (3) Any business conducted by a partnership shall be treated as ...
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56
Wisconsin Legislature: Tax 2.62
https://docs.legis.wisconsin.gov/code/admin_code/tax/2/62
Tax 2.62(2)(c)1.1. In general, the participants in a commonly controlled economic enterprise are considered a unitary business if their activities generate a ...
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https://docs.legis.wisconsin.gov/code/admin_code/tax/2/62
Tax 2.62(2)(c)1.1. In general, the participants in a commonly controlled economic enterprise are considered a unitary business if their activities generate a ...
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57
Maryland Court Says Unitary Relationship Creates Nexus
https://www.lexisnexis.com/legalnewsroom/tax-law/b/lexistaxstaffcommentaries/posts/maryland-court-says-unitary-relationship-creates-nexus
› tax-law › posts › marylan...
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https://www.lexisnexis.com/legalnewsroom/tax-law/b/lexistaxstaffcommentaries/posts/maryland-court-says-unitary-relationship-creates-nexus
› tax-law › posts › marylan...
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58
Timing Is Everything: When Do Assets and Entities Become ...
https://www.alvarezandmarsal.com/insights/timing-everything-when-do-assets-and-entities-become-unitary
For example, when one entity acquires another entity that engages in a similar line of business, it is often clear that a unitary relationship ...
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https://www.alvarezandmarsal.com/insights/timing-everything-when-do-assets-and-entities-become-unitary
For example, when one entity acquires another entity that engages in a similar line of business, it is often clear that a unitary relationship ...
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59
Chapter 8: Business and Nonbusiness Earnings | TN.gov
https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/fae_tax/Chapter%208%20-%20Business%20and%20Nonbusiness%20Earnings%20-%20March%202021.pdf
Business earnings that are not unitary to a taxpayer's business ... In connection with that business, the taxpayer maintains special.
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https://www.tn.gov/content/dam/tn/revenue/documents/tax_manuals/fae_tax/Chapter%208%20-%20Business%20and%20Nonbusiness%20Earnings%20-%20March%202021.pdf
Business earnings that are not unitary to a taxpayer's business ... In connection with that business, the taxpayer maintains special.
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60
Insurance Company AIG Is Not Unitary with Wholly Owned Ski ...
https://www.lanepowell.com/portalresource/PDF_Article_KittleD_Insurance%20Company%20AIG%20Is%20Not%20Unitary%20with%20Wholly%20Owned%20Ski%20Res
are "unitary businesses" requires a highly ... unitary business for Vermont income tax reporting purposes. ... sis of whether the relationship between.
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https://www.lanepowell.com/portalresource/PDF_Article_KittleD_Insurance%20Company%20AIG%20Is%20Not%20Unitary%20with%20Wholly%20Owned%20Ski%20Res
are "unitary businesses" requires a highly ... unitary business for Vermont income tax reporting purposes. ... sis of whether the relationship between.
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61
A PINCH OF SALT
https://www.pillsburylaw.com/images/content/1/2/v2/123221/What-NY-Can-Learn-from-California-s-Combined-Reporting-History-S.pdf
ern definition of a unitary business in 1980,1 California had ... to whether a unitary relationship exists among the affili-.
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https://www.pillsburylaw.com/images/content/1/2/v2/123221/What-NY-Can-Learn-from-California-s-Combined-Reporting-History-S.pdf
ern definition of a unitary business in 1980,1 California had ... to whether a unitary relationship exists among the affili-.
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62
Combined Reporting - WV State Tax Department
https://tax.wv.gov/Documents/Reports/CombinedReportingBrochure.pdf
which require mandatory unitary combined reporting of income for ... A working relationship between ... business, the unitary group.
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https://tax.wv.gov/Documents/Reports/CombinedReportingBrochure.pdf
which require mandatory unitary combined reporting of income for ... A working relationship between ... business, the unitary group.
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63
Chapter 801: APPORTIONMENT - Maine.gov
https://www.maine.gov/revenue/sites/maine.gov.revenue/files/inline-files/Rule_801_April_2022.pdf
corporations constitute a unitary business if those activities are ... minimal fee bears no relationship to the volume of the taxpayer's business activity.
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https://www.maine.gov/revenue/sites/maine.gov.revenue/files/inline-files/Rule_801_April_2022.pdf
corporations constitute a unitary business if those activities are ... minimal fee bears no relationship to the volume of the taxpayer's business activity.
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64
Unitary Business Principle - state income taxes - StuDocu
https://www.studocu.com/en-us/document/drexel-university/state-and-local-tax/unitary-business-principle/29543486
Unitary Business Principle: If a company is determined to be a unitary business, then a state may apportion the taxpayer's total income to obtain a rough ...
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https://www.studocu.com/en-us/document/drexel-university/state-and-local-tax/unitary-business-principle/29543486
Unitary Business Principle: If a company is determined to be a unitary business, then a state may apportion the taxpayer's total income to obtain a rough ...
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65
Spring 2018 STARTUP Conference Unitary
https://us.eversheds-sutherland.com/portalresource/lookup/poid/Z1tOl9NPluKPtDNIqLMRV56Pab6TfzcRXncKbDtRr9tObDdEpK3Ema3!/fileUpload.name=/StartupUnitary.pdf
The connection and relationship relate to the income that arises from a unitary business. 9. Page 10. Eversheds Sutherland. Three Unities Test.
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https://us.eversheds-sutherland.com/portalresource/lookup/poid/Z1tOl9NPluKPtDNIqLMRV56Pab6TfzcRXncKbDtRr9tObDdEpK3Ema3!/fileUpload.name=/StartupUnitary.pdf
The connection and relationship relate to the income that arises from a unitary business. 9. Page 10. Eversheds Sutherland. Three Unities Test.
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66
State Taxation of Unitary Businesses - Fordham Law
https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=1498&context=ulj
contrasted and their relationship to the unitary business concept explained. The conclusion will summarize the discussion in part III.
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https://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=1498&context=ulj
contrasted and their relationship to the unitary business concept explained. The conclusion will summarize the discussion in part III.
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67
refinement of the unitary business doctrine in meadwestvaco ...
http://www.law.siu.edu/_common/documents/law-journal/articles-2010/bennett-casenote.pdf
relationship or even a unitary relationship between two businesses, there must be some connection between the taxing state and the value it seeks to tax.3 ...
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http://www.law.siu.edu/_common/documents/law-journal/articles-2010/bennett-casenote.pdf
relationship or even a unitary relationship between two businesses, there must be some connection between the taxing state and the value it seeks to tax.3 ...
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68
150-317.705(3)(a) Unitary Business - Oregon.gov
https://www.oregon.gov/DOR/about/Rules/150-317.705(3)(a)_Unitary_Business.pdf
business. This amendment specifies that common ownership of greater than 50% is required to establish a unitary relationship between two or ...
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https://www.oregon.gov/DOR/about/Rules/150-317.705(3)(a)_Unitary_Business.pdf
business. This amendment specifies that common ownership of greater than 50% is required to establish a unitary relationship between two or ...
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69
Unitary Tax System - Explained - The Business Professor, LLC
https://thebusinessprofessor.com/accounting-taxation-and-reporting-taxation/unitary-tax-system-definition
› unitary-tax-system-d...
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https://thebusinessprofessor.com/accounting-taxation-and-reporting-taxation/unitary-tax-system-definition
› unitary-tax-system-d...
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70
NYS Tax Appeals Tribunal Provides Guidance Respecting ...
https://www.insidesalt.com/2015/06/nys-tax-appeals-tribunal-provides-guidance-respecting-unitary-business-determinations/
The unitary business rules have assumed increased importance in New ... held to be a further indicator of a unitary business relationship.
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https://www.insidesalt.com/2015/06/nys-tax-appeals-tribunal-provides-guidance-respecting-unitary-business-determinations/
The unitary business rules have assumed increased importance in New ... held to be a further indicator of a unitary business relationship.
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71
Massachusetts blocks tax of nondomiciliary corporation gain
https://www.pwc.com/us/en/services/tax/library/massachusetts-blocks-tax-of-nondomiciliary-corporation-gain.html
The takeaway: The SJC's decision in VAS Holdings is a reminder for taxpayers that the existence of a unitary business relationship between a ...
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https://www.pwc.com/us/en/services/tax/library/massachusetts-blocks-tax-of-nondomiciliary-corporation-gain.html
The takeaway: The SJC's decision in VAS Holdings is a reminder for taxpayers that the existence of a unitary business relationship between a ...
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72
Non-Unitary Relationships with Flow-Through Entities
https://www.taxformfinder.org/forms/2015/2015-michigan-form-4898.pdf
Taxpayer Name (If Unitary Business Group, Name of Designated Member) ... Corporate Income Tax: Non-Unitary Relationships with Flow-Through Entities. Purpose.
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https://www.taxformfinder.org/forms/2015/2015-michigan-form-4898.pdf
Taxpayer Name (If Unitary Business Group, Name of Designated Member) ... Corporate Income Tax: Non-Unitary Relationships with Flow-Through Entities. Purpose.
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73
SC Revenue Advisory Bulletin #01-1
https://dor.sc.gov/resources-site/lawandpolicy/Advisory%20Opinions/RAB01-1.pdf
determined under the principles relating to a unitary business as set forth in the ... integrated relationship between the subsidiaries and the taxpayer.
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https://dor.sc.gov/resources-site/lawandpolicy/Advisory%20Opinions/RAB01-1.pdf
determined under the principles relating to a unitary business as set forth in the ... integrated relationship between the subsidiaries and the taxpayer.
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74
Unitary Tax Definition | Law Insider
https://www.lawinsider.com/dictionary/unitary-tax
Unitary business means one or more related business organizations engaged in business activity both within and outside the State among which there exists a ...
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https://www.lawinsider.com/dictionary/unitary-tax
Unitary business means one or more related business organizations engaged in business activity both within and outside the State among which there exists a ...
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75
An Examination of Mobil Oil Corp. v. Commissioner of Taxes of
https://digitalcommons.law.byu.edu/cgi/viewcontent.cgi?article=1353&context=lawreview&httpsredir=1&referer=
ment of income related to a unitary trade or business. It also ... part of its worldwide petroleum business in connection with the.
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https://digitalcommons.law.byu.edu/cgi/viewcontent.cgi?article=1353&context=lawreview&httpsredir=1&referer=
ment of income related to a unitary trade or business. It also ... part of its worldwide petroleum business in connection with the.
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76
Combined Reporting with the Corporate Income Tax: Issues ...
https://www.ncsl.org/documents/standcomm/sccomfc/CombinedReportingFinalDraft.pdf
Defining the unitary group is further made difficult by business ownership of ... ownership and business relationships to determine the filing group.
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https://www.ncsl.org/documents/standcomm/sccomfc/CombinedReportingFinalDraft.pdf
Defining the unitary group is further made difficult by business ownership of ... ownership and business relationships to determine the filing group.
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77
Definition of a Unitary Business
https://img1.wsimg.com/blobby/go/8a8178fe-c08a-4991-86c9-9624af5c4079/downloads/Portfolios%20--%20i)%20Definition%20of%20a%20Unitary%20Busin.pdf?ver=1645083785738
STATE STANDARDS IN DEFINING A UNITARY BUSINESS. A. Evolving Views of Unity Embrace a Greater Range of Relationships. 1. Multistate Tax Commission Proposed ...
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https://img1.wsimg.com/blobby/go/8a8178fe-c08a-4991-86c9-9624af5c4079/downloads/Portfolios%20--%20i)%20Definition%20of%20a%20Unitary%20Busin.pdf?ver=1645083785738
STATE STANDARDS IN DEFINING A UNITARY BUSINESS. A. Evolving Views of Unity Embrace a Greater Range of Relationships. 1. Multistate Tax Commission Proposed ...
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78
2021 Form 6 Instructions for Combined Returns
https://www.revenue.wi.gov/TaxForms2021/2021-Form6-Inst.pdf
doing business in Wisconsin that relates to the common unitary business, ... foreign income tax paid in connection with a covered asset acquisition, ...
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https://www.revenue.wi.gov/TaxForms2021/2021-Form6-Inst.pdf
doing business in Wisconsin that relates to the common unitary business, ... foreign income tax paid in connection with a covered asset acquisition, ...
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79
Indiana Tax Developments: Fall 2020 - Dentons
https://www.dentons.com/en/insights/articles/2020/october/30/indiana-tax-developments-fall-2020
Taxpayer protested the assessment as to Gas Station LLC only, arguing that the two shared a unitary business relationship and that income from ...
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https://www.dentons.com/en/insights/articles/2020/october/30/indiana-tax-developments-fall-2020
Taxpayer protested the assessment as to Gas Station LLC only, arguing that the two shared a unitary business relationship and that income from ...
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80
06-1413 MeadWestvaco Corp. v. Illinois Dept. of Revenue (4 ...
https://www.supremecourt.gov/opinions/07pdf/06-1413.pdf
being done in connection with this case, at the time the opinion ... taxpayer's unitary business even without a “unitary relationship” be-.
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https://www.supremecourt.gov/opinions/07pdf/06-1413.pdf
being done in connection with this case, at the time the opinion ... taxpayer's unitary business even without a “unitary relationship” be-.
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81
Supreme Court to Reconsider Unitary-Business Concept
https://search.proquest.com/openview/921dba70fce74ca0740eb1754174b7d3/1?pq-origsite=gscholar&cbl=48426
by S Barlas · 1992 —
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https://search.proquest.com/openview/921dba70fce74ca0740eb1754174b7d3/1?pq-origsite=gscholar&cbl=48426
by S Barlas · 1992 —
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82
state taxation-unitary business / formula - Digital Commons
https://digitalcommons.law.uga.edu/cgi/viewcontent.cgi?article=1530&context=gjicl
unitary business or formula apportionment method of income allocation, known as the ... uniformity in regulating international commercial relations.
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https://digitalcommons.law.uga.edu/cgi/viewcontent.cgi?article=1530&context=gjicl
unitary business or formula apportionment method of income allocation, known as the ... uniformity in regulating international commercial relations.
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83
IS A NON-UNITARY, OUT-OF-STATE PARTNER SUBJECT ...
https://www.floridasalestax.com/florida-tax-law-blog/2011/december/florida-tax-litigation-alert-vodafone-is-a-non-u/
Alternatively, even if the income was part of a unitary business, ... Therefore, VAI's only connection with the state of Florida was its ...
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https://www.floridasalestax.com/florida-tax-law-blog/2011/december/florida-tax-litigation-alert-vodafone-is-a-non-u/
Alternatively, even if the income was part of a unitary business, ... Therefore, VAI's only connection with the state of Florida was its ...
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84
UPDATE: Ohio House Bill Clarifies Income Tax Treatment of ...
https://www.taftlaw.com/news-events/law-bulletins/update-ohio-house-bill-clarifies-income-tax-treatment-of-the-sale-of-a-business-interest
... had a unitary business relationship with the business being sold. ... The clarification of income from the sale of a business as ...
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https://www.taftlaw.com/news-events/law-bulletins/update-ohio-house-bill-clarifies-income-tax-treatment-of-the-sale-of-a-business-interest
... had a unitary business relationship with the business being sold. ... The clarification of income from the sale of a business as ...
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85
New Jersey Unitary Business Test & Combined Reporting (TB
https://www.cohnreznick.com/insights/nj-provides-guidance-on-unitary-business-test-and-combined-reporting-requirement
The New Jersey Division of Taxation has provided technical guidance (TB- 93) regarding its unitary business test. As previously discussed ...
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https://www.cohnreznick.com/insights/nj-provides-guidance-on-unitary-business-test-and-combined-reporting-requirement
The New Jersey Division of Taxation has provided technical guidance (TB- 93) regarding its unitary business test. As previously discussed ...
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86
Chapter 24 - Apportionment - Nebraska Department of Revenue
https://revenue.nebraska.gov/about/legal-information/regulations/chapter-24-apportionment
315.02A When a partnership has sufficient contacts with a business entity to be considered unitary if it were a corporation, the partnership will be considered ...
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https://revenue.nebraska.gov/about/legal-information/regulations/chapter-24-apportionment
315.02A When a partnership has sufficient contacts with a business entity to be considered unitary if it were a corporation, the partnership will be considered ...
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87
Chapter 7 Corporate Franchise and Income Taxes Part 1 ...
https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.pdf
all members of a unitary group irrespective of the country in which the corporations are incorporated or conduct business activity. Amended by Chapter 368, ...
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https://le.utah.gov/xcode/Title59/Chapter7/C59-7_1800010118000101.pdf
all members of a unitary group irrespective of the country in which the corporations are incorporated or conduct business activity. Amended by Chapter 368, ...
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88
Tribunal reverses ALJ and permits combination based on ...
https://www.lexology.com/library/detail.aspx?g=a6362949-4fda-4b0a-89b3-5a3aa171e76a
... ALJ and permits combination based on unitary business and distortion ... a unitary business relationship and proof of actual distortion.
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https://www.lexology.com/library/detail.aspx?g=a6362949-4fda-4b0a-89b3-5a3aa171e76a
... ALJ and permits combination based on unitary business and distortion ... a unitary business relationship and proof of actual distortion.
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89
Franchise Tax - LEGISLATIVE GUIDE - Iowa.gov
https://www.legis.iowa.gov/docs/publications/LG/24337.pdf
For Iowa corporate income tax purposes these business entities are ... corporation to be part of unitary business because relationship produced “economies ...
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https://www.legis.iowa.gov/docs/publications/LG/24337.pdf
For Iowa corporate income tax purposes these business entities are ... corporation to be part of unitary business because relationship produced “economies ...
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90
State of Rhode Island and Providence Plantations
https://tax.ri.gov/sites/g/files/xkgbur541/files/regulations/other/CT16-17_Combined_Reporting.pdf
connection” necessary for this state to apportion income of the unitary business, even if that income arises in part from activities ...
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https://tax.ri.gov/sites/g/files/xkgbur541/files/regulations/other/CT16-17_Combined_Reporting.pdf
connection” necessary for this state to apportion income of the unitary business, even if that income arises in part from activities ...
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91
MULTI-STATE CORPORATE INCOME TAX ISSUES
https://www.steptoe.com/a/web/1591/2551.pdf
(1) Due Process Clause – “Minimum Connection.” The Due Process ... "unitary business," a State must then apply a formula apportioning the income of that.
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https://www.steptoe.com/a/web/1591/2551.pdf
(1) Due Process Clause – “Minimum Connection.” The Due Process ... "unitary business," a State must then apply a formula apportioning the income of that.
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92
U.S. Perspectives of Worldwide Unitary Taxation
https://elibrary.law.psu.edu/cgi/viewcontent.cgi?article=1092&context=psilr
tion,1 threats to the international economic relations, and the reac- ... scope of the unitary business to the domestic operations of affiliates.
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https://elibrary.law.psu.edu/cgi/viewcontent.cgi?article=1092&context=psilr
tion,1 threats to the international economic relations, and the reac- ... scope of the unitary business to the domestic operations of affiliates.
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93
Does Georgia Need A Unitary Tax?
https://cslf.gsu.edu/files/2014/06/does_georgia_need_a_unitary_tax.pdf
a unitary business is defined, then the determination of the corporate income ... the state can not tax without a proper connection between the taxpayer and ...
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https://cslf.gsu.edu/files/2014/06/does_georgia_need_a_unitary_tax.pdf
a unitary business is defined, then the determination of the corporate income ... the state can not tax without a proper connection between the taxpayer and ...
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94
Instructions for Form 4580 Michigan Business Tax (MBT ...
https://eformrs.com/Forms10/States10/MI/MI4580.PDF
RAB 2010-2, MBT—Unitary Business Group Relationship. Tests, on the Department of Treasury (Treasury) Web site at www.michigan.gov/taxes.
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https://eformrs.com/Forms10/States10/MI/MI4580.PDF
RAB 2010-2, MBT—Unitary Business Group Relationship. Tests, on the Department of Treasury (Treasury) Web site at www.michigan.gov/taxes.
→ Check Latest Keyword Rankings ←
95
MICHIGAN CORPORATE INCOME TAX
https://www.michiganbusiness.org/4a8165/globalassets/documents/reports/fact-sheets/mi-cit.pdf
to file under the current Michigan Business Tax (MBT) structure. ... The CIT requires unitary business groups to file a ... the group (“Relationship Test”).
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https://www.michiganbusiness.org/4a8165/globalassets/documents/reports/fact-sheets/mi-cit.pdf
to file under the current Michigan Business Tax (MBT) structure. ... The CIT requires unitary business groups to file a ... the group (“Relationship Test”).
→ Check Latest Keyword Rankings ←
96
Partnership Return Booklet - State Forms Online Catalog
https://forms.in.gov/Download.aspx?id=7549
The relationship be- tween the business of the corporate partner and the partnership con- trols the classification. Non-unitary partnership income ...
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https://forms.in.gov/Download.aspx?id=7549
The relationship be- tween the business of the corporate partner and the partnership con- trols the classification. Non-unitary partnership income ...
→ Check Latest Keyword Rankings ←
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