Download or read book Federal Tax Concepts as a Guide for State Apportionment of Dividends written by Richard D. Pomp and published by . This book was released on 2019 with total page 18 pages. Available in PDF, EPUB and Kindle. Book excerpt: In ASARCO, Inc. v. Idaho State Tax Commission, the Supreme Court rejected Idaho's definition of income, and limited the apportionability of dividends, interest, and capital gains. The Court held that a unitary business relationship did not exist between ASARCO and the dividend payors, but did not address whether such a relationship was a sufficient precondition or a necessary one. This article addresses two federal tax doctrines that may provide insight into state taxation of dividends: (1) the “effectively connected” doctrine, and (2) the Corn Products doctrine. The article first provides a detailed examination of the facts in ASARCO, and discusses the Court's holding. The article explains that Idaho's sweeping definition of income, which conflated business and nonbusiness income, invited the Court's rejection. Next, the article examines the applicability of Mobil Oil Corp. v. Commissioner of Taxes of Vermont, and how that holding is not dispositive regarding the apportionability of dividends in general. Finally, the article discusses the two aforementioned federal tax doctrines. These two doctrines do not expressly address the characterization of dividends as business income, but implicate the same underlying issue. The article concludes by explaining that the tax treatment of dividends and capital gains as business income is not unique to state taxation.

Download or read book Special Report of Idaho Tax Commission on the Tax Situation in the State of Idaho written by Idaho. Tax commission and published by . This book was released on 1914 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Biennial Report of the State Tax Commission of the State of Idaho written by Idaho. State Tax Commission and published by . This book was released on 1979 with total page 130 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Report of Idaho State Tax Commission Meeting May 5 1947 Boise Id written by Idaho. State Tax Commission and published by . This book was released on 1947 with total page 3 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Annual Report of the State Tax Commission of the State of Idaho Property Division written by Idaho. State Tax Commission. Property Division and published by . This book was released on 1968 with total page 474 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Report of the State Tax Commission to the 39th Session of the Idaho Legislature written by Idaho. State Tax Commission and published by . This book was released on 1967 with total page 31 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Papers and Proceedings Idaho State Tax Institute written by Idaho State Tax Institute and published by . This book was released on 1967 with total page 152 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Idahoan s Tax Burden Relative to Other States written by Idaho. State Tax Commission and published by . This book was released on 1974 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Idaho State Tax Commission Multi state Corporate Tax Compromise and Close Agreements written by Idaho. Legislature. Legislative Services Office and published by . This book was released on 1996 with total page 19 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Official Reports of the Supreme Court written by United States. Supreme Court and published by . This book was released on 2008-04 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book United States Reports written by United States. Supreme Court and published by . This book was released on 2012 with total page 1150 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Trinova Corporation v Department of Treasury 433 MICH 141 1989 written by and published by . This book was released on 1989 with total page 78 pages. Available in PDF, EPUB and Kindle. Book excerpt: 82673

Download or read book Unitary Tax written by United States. Congress. Senate. Committee on Foreign Relations. Subcommittee on International Economic Policy and published by . This book was released on 1985 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Integration Approaches to Group Taxation in the European Internal Market written by Ioanna Mitroyanni and published by Kluwer Law International B.V.. This book was released on 2008-10-13 with total page 411 pages. Available in PDF, EPUB and Kindle. Book excerpt: The creation of a group taxation framework to subject affiliated entities resident in more than one EC Member State to a single set of rules is an experiment without precedent. Group taxation normally deals with tax liability in the context of a single jurisdiction. There is no system of group taxation worldwide which embraces more than one fiscal jurisdiction under a single regulatory umbrella. This thought provoking work explores the prospect for creating a group taxation system extending across national borders in the EC. The objective is to specify what shape the elements of such a system should take as well as to identify the areas of complexity or probable impasse. Among the topics covered. The relevant jurisprudential and legislative framework of the European Internal Market; A survey of the tax systems of Canada, Switzerland and the US with a focus on the principles pertaining to the division of power between the federal and sub-federal tiers; The policies for corporate taxation in integrated markets; Administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability; Tests for entitlement to group membership; Tax base integration; - Territorial delineation of the group; and Formulary apportionment. In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well.

Download or read book State Corporation Income Tax Issues in Worldwide Unitary Combination written by and published by Hoover Press. This book was released on 1984 with total page 394 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Foreign Direct Investment and the Multinational Enterprise A Bibliography written by Cynthia Day Wallace and published by Martinus Nijhoff Publishers. This book was released on 1988-02 with total page 367 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book California Supreme Court Records and Briefs written by California (State). and published by . This book was released on with total page 62 pages. Available in PDF, EPUB and Kindle. Book excerpt: