The author discusses the evolution of state income taxation for a multijurisdictional unitary business beginning with the early property tax cases, and reviews how this concept has been refined over the years. Next, the formulary apportionment of unitary business income is analyzed with particular emphasis placed on the sometimes distortive results. Finally, the United States Supreme Court's recent decision in Container Corporation of America is evaluated, with a view towards the future implications for state income tax practitioners.
Garet H. Danvers,
State Income Taxation of Multijurisdictional Corporations: An Historical Perspective,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol22/iss4/8