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Multistate Corporation Allocation And Apportionment Links:

• Allied-Signal v. Director, Division of Taxation, 504 U.S. 768 (1992)
  Unitary business principle. ASARCO and Woolworth upheld; apportionable part of gain on sale of stock is taxable.
  

• Barclay's Bank PLC v. Franchise Tax Bd., 512 U.S. 298  (1994)
  Application of Complete Auto's guides and "additional scrutiny" required when a State seeks to tax foreign commerce: 1. the enhanced risk of multiple taxation, and 2. impairment of federal uniformity in an area where federal uniformity is essential.
  

• Butler Brothers v. McColgan, 315 U.S. 501 (1942)
  Distinguised Han Rees' Sons and held that apportionment of unitary income was appropriate. Separate accounting analysis rejected.
  

• Colgate-Palmolive Company, v. Franchise Tax Board of California, 512 U.S. 298 (1994)
  California franchise tax. Cite as 512 U.S. 298, 114 S.Ct. 2268, 129 L.Ed.2d 244 (1994). Commerce and Due Process Clauses. Application of Complete Auto's guides and "additional scrutiny" required when a State seeks to tax foreign commerce: 1. the enhanced risk of multiple taxation, and 2. impairment of federal uniformity in an area where federal uniformity is essential (speaking with one voice in international trade). See also Barclay's Bank PLC v. Franchise Tax Bd., 512 U.S. 298  (1994)
  

• Container Corp. v. Franchise Tax Bd., 463 U.S. 159 (1983)
  Unitary business concept - fair apportionment - Foreign Commerce Clause - "arm's-length" analysis.
  

• Hans Rees' Sons v. State of North Carolina, 283 U.S. 123 (1931)
  Commerce clause violated by apportionment method which operated unreasonably and arbitrarily.
  

• Norfolk & Western Railroad Co. v. Tax Commission, 390 U.S. 317 (1968)
  Due Process and Commerce Clauses violated by mileage formula which amounted to a tax on out-of-state property.
  

Multistate Corporation Allocation And Apportionment Related Categories:

• Multistate : Corporate Income Tax : Payroll Factor
• Multistate : Corporate Income Tax : Property Factor
• Multistate : Corporate Income Tax : Sales Factor

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