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Income and Apportionment Issues for Institutions With Locations in Multiple States  


Author:  Roy E.  Crawford.


Source: Volume 24, Number 05, May/June 2011 , pp.47-51(5)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

This column addresses the difficulty of locating loans in the property factor when apportioning the net income of multistate financial institutions, looking specifically at the recently withdrawn Idaho rules that would have amended the MTC recommended formula, and also considers state “add back” statutes that require the addition to income of interest, royalties, rent, and similar expenses when paid to an affiliate.

Keywords: sourcing loans, preponderance of substantive contacts, property factor, SINAA rules, add-back statute, interest expense disallowance, Beneficial New Jersey Inc. v. Director

Affiliations:  1: McDermott Will & Emery.

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