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State Corporate Income Tax Unitary Business Links:

• Allied-Signal v. Director, Division of Taxation, 504 U.S. 768 (1992) Site Preview & Search
  New Jersey corporate income tax. Cite as 504 U.S. 768, 112 S.Ct. 2251, 119 L.Ed.2d 533 (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) Site Preview & Search
  California franchise tax. Cite as 315 U.S. 501, 62 S.Ct. 701, 86 L.Ed. 991 (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) Site Preview & Search
  California franchise tax. Cite as 463 U.S. 159, 103 S.Ct. 2933, 77 L.Ed. 2d 545 (1983). Unitary business concept; fair apportionment; Foreign Commerce Clause and "arm's-length" analysis.
  

• Water's Edge Manual (CA) Site Preview & Search
  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 2000).