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- 3000 UNITY - Franchise Tax Board
3000 UNITY R TC §25101 provides that when the income of a taxpayer is attributable to sources both within and without California, the taxpayer is required to measure its franchise tax liability by its income attributable to sources within the state The portion of the total income that is considered to be attributable to California is determined in accordance with unitary business principles
- Income Apportionment and Allocation after Mead - The Tax Adviser
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 of the corporate group can become part of the group’s apportionable tax base in that state if the group and the member are deemed unitary
- Cal. Code Regs. Tit. 18, §§ 25106. 5-10 | State Regulations . . .
(1) Unitary Business A taxpayer is engaged in a unitary business (or a single business within the meaning of Reg 25120 (b)) when its activities within the state contribute to or are dependent upon its activities without the state A unitary business exists when there is unity of ownership, unity of operation and unity of use
- 15-31-301. Corporations subject to allocation and . . .
15-31-301 Corporations subject to allocation and apportionment (1) Any corporation having income from business activity which is taxable both within and without this state shall allocate and apportion its net income as provided in this part (2) A corporation engaged in a unitary business within and without Montana must apportion its apportionable income as provided for under 15-31-305 A
- California CPA for Unitary Determinations - Cook CPA Group
To determine the amount of income that was made within the state of California, the unitary business principle is used The groups of business activities that are combined into one report are known as a unitary business group and can be comprised of either vertically or horizontally integrated businesses
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