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State Corporate Income Tax Unitary Business 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.
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.
Container Corp. v. Franchise Tax Bd., 463 U.S. 159 (1983) Unitary business concept - fair apportionment - Foreign Commerce Clause - "arm's-length" analysis.
Water's Edge Manual (CA) Introduces the water's-edge law in terms of its general outline and key features, its history, and its relationship to the federal international tax system. Discusses audit problems, techniques and specialized procedures. Contains guidance for resolving special issues that auditors encounter (Revised: January 2004).