(Download) "Craig v. Brown & Root" by California Court of Appeals " Book PDF Kindle ePub Free

eBook details

Title: Craig v. Brown & Root
Author : California Court of Appeals
Release Date : January 26, 2000
Genre: Law,Books,Professional & Technical,
Pages : * pages
Size : 60 KB

Description

States have long struggled to devise an equitable and constitutional method for taxing corporations that do business in multiple states and countries. Like many other states, California has adopted the Uniform Division of Income for Tax Purposes Act (7A pt. 1 Wests U. Laws Ann. (1999) U. Div. of Income for Tax Purposes Act, Â§ 1 et seq., p. 361) (UDITPA) in an attempt to resolve this dilemma (see Rev. & Tax. Code, Â§Â§ 25120-25141). Under this scheme of taxation, all taxpayer income is divided into business or nonbusiness income. Business income is apportionable to each state using a three-factor formula. Nonbusiness income is allocable only to the taxpayers commercial domicile. In this case, we consider whether a reversion of surplus pension plan assets is taxable by California as apportionable business income. We conclude that it is.