Fair apportionment is a constitutional requirement. According to Complete Auto Transit Inc. v. Brady, 430 U.S. 274 (1977), to be fairly apportioned, a state tax on corporate income must be limited to ...

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in ...

Why only seek an alternative formula when you can win under the normal formula? A corporate taxpayer won under a special-industry normal apportionment formula, and it won the right to use an ...

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When a taxpayer arguing for its appropriate apportionment can present solid testimony regarding how and where its business is conducted and the economics attributable to the parts of the business, the ...

Applying the time-based apportionment formulas to determine capital gains can have absurd results and seriously prejudice taxpayers. The attempt at simplicity has resulted in a lack of equity in the ...

This is the last of four posts that discuss the original legal force of the terms the Constitution employs to denote financial exactions. This series is based, for the most part, on my forthcoming ...

Technology is enabling businesses to perform tasks more efficiently and provide services to customers in ways they never thought possible. Yet these novel processes and products present considerable ...