Laws and Rules

Idaho combined reporting

Learn more:

Court decisions

  • Underwood Typewriter Co. v Chamberlain, 254 U.S. 113 (1920) – apportionment of a single corporation’s income was justified rather than allocating profits based only on activity in a state
  • Bass, Ratcliff & Gretton Ltd. v. State Tax Commission, 266 U.S. 271 (1924) – Apportionment formula allowed to worldwide profits even though state activity reflected a loss
  • Butler Bros. v. McColgan, 17 Cal. 2d 664, 111 Pac. 2d 334, aff’d 315 U.S. 501 (1942) – defined unitary business through unity of ownership, operation, and use and determined unitary business of a single corporation and its various divisions
  • Edison California Stores v. McColgan, 30 Cal. 2d. 472, 183 Pac. 2d 16 (1947) – contribution or dependency test used to determine unitary business and applied to a multi-corporate group
  • Container Corp. of America v. Franchise Tax Board, 463 U.S. 159, 103, S. Ct. 2933 (1983) – explicit approval of worldwide unitary business principle based on flow of value from functional integration, centralized management, and economies of scale. “Rejects geographical or transaction accounting.” Domestic parent
  • Albertson’s Inc. v. Department of Revenue, 106 Idaho 810, 683 P.2d 846 (1984) – Idaho Supreme Court unanimous approval of the combined reporting method including distributive share of 50% interest in partnership’s income, deductions and apportionment factors
  • Allied-Signal Inc. v. Director Division of Taxation, 504 U.S. 768 (1992) – provided that apportionment is appropriate when income from an asset serves an operational rather than an investment function in the taxpayer’s business
  • Barclays Bank PLC v. Franchise Tax Board of California, 512 U.S. 298 (1994) – upheld unitary business principle when there exists a foreign parent