CHAPTER 16—MULTISTATE CORPORATE TAXATION

1916. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #1
Compute Quail Corporation’s State Q taxable income for the year.

Addition modifications

$50,000

Allocated income – total

$80,000

Allocated income – State Q

$50,000

Allocated income – State P

$30,000

Apportionment percentage

20%

Federal taxable income

$200,000

State tax credits

$3,000

Subtraction modifications

$30,000

Tax rate

5%

1917. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #2
Node Corporation is subject to tax only in State X. Node generated the following income and deductions. State income taxes are not deductible for X income tax purposes.

Sales

$5,000,000

Cost of sales

3,000,000

State X income tax expense

60,000

Depreciation allowed for Federal tax purposes

1,000,000

Depreciation allowed for state tax purposes

1,800,000

Interest income on Federal obligations

50,000

Interest income on X obligations

200,000

Expenses related to carrying X obligations

30,000

a.

The starting point in computing the X income tax base is Federal taxable income. Derive this amount.

b.

Determine Node’s X taxable income, assuming that interest on X obligations is exempt from X income tax.

c.

Determine Node’s taxable income, assuming that interest on X obligations is subject to X income tax.

1918. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #3
Provide the required information for Wren Corporation, whose Federal taxable income totals $100 million. Wren apportions 60% of its business income to State C. Wren generates $10 million of nonbusiness income each year. Forty percent of that income is attributable to rentals of buildings located in C. Wren’s business income this year totals $60 million.

a.

State C taxes how much of Wren’s business income?

b.

State C taxes how much of Wren’s nonbusiness income?

c.

Explain your results.

1919. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #4
Condor Corporation generated $450,000 of state taxable income from selling its product in States A and B. For the taxable year, the corporation’s activities within the two states were as follows.

State A

State B

Total

Sales

$800,000

$200,000

$1,000,000

Property

300,000

–0–

300,000

Payroll

200,000

800,000

1,000,000

Condor has determined that it is subject to tax in both A and B. Both states utilize a three-factor apportionment formula that equally weights sales, property, and payroll. The rates of corporate income tax imposed in A and B are 5% and 3%, respectively. Determine Condor’s state income tax liability.

1920. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #5
Milt Corporation owns and operates two facilities that manufacture paper products. One of the facilities is located in State D, and the other is located in State E. Milt generated $1,200,000 of taxable income, comprised of $1,000,000 of income from its manufacturing facilities and a $200,000 gain from the sale of nonbusiness property located in E. E does not distinguish between business and nonbusiness property. D apportions business income. Milt’s activities within the two states are outlined below.

State D

State E

Total

Sales of paper products

$4,500,000

$1,500,000

$6,000,000

Property

3,500,000

2,500,000

6,000,000

Payroll

1,500,000

1,000,000

2,500,000

Both D and E utilize a three-factor apportionment formula, under which sales, property, and payroll are equally weighted. Determine the amount of Milt’s income that is subject to income tax by each state.

1921. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #6
Dott Corporation generated $300,000 of state taxable income from selling its mapping software in States A and B. For the taxable year, the corporation’s activities within the two states were as follows.

State A

State B

Total

Sales

$500,000

$1,500,000

$2,000,000

Property

250,000

–0–

250,000

Payroll

200,000

300,000

500,000

Dott has determined that it is subject to tax in both A and B. Both states utilize a three-factor apportionment formula which equally weights sales, property, and payroll. The rates of corporate income tax imposed in A and B are 7% and 10%, respectively. Determine Dott’s state income tax liability.

1922. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #7
Shaker Corporation operates in two states, as indicated below. All goods are manufactured in State A. Determine the sales to be assigned to both states to be used in computing Shaker’s sales factor for the year. Both states follow the UDITPA and the MTC regulations in this regard.

State A

State B

Gross sales to purchasers in state

$200,000

$350,000

Sales returns

9,000

11,000

Discounts allowed

21,000

41,000

Carrying charges collected back from customers

20,000

10,000

Rental income

50,000*

25,000**

* Excess warehouse space
** Land held for speculation

1923. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #8
Determine Bowl’s sales factors for States K, M, and N.

Bowl Corporation’s manufacturing facility, distribution center, and retail store are located in State K. Bowl sells its products to residents located in States K, M, and N.

Sales to residents of K are conducted through a retail store. Sales to residents of M are obtained by Bowl’s sales representative, who has the authority to accept and approve sales orders. Residents of N can purchase Bowl’s product only if they place an order online and arrange to take delivery of the product at Bowl’s shipping dock. Bowl’s sales were as follows.

Sales to residents of State K

$1,000,000

Sales to residents of State M

900,000

Sales to residents of State N

600,000

Total

$2,500,000

Bowl’s activities within the three states are limited to those described above. All of the states have adopted a throwback provision and utilize a three-factor apportionment formula under which sales, property, and payroll are equally weighted. K sources dock sales to the destination state.

%

* The throwback rule is an exception to the ultimate destination test. This rule ensures the taxation of sales made in a destination state that does not have sufficient nexus under which to tax the corporation. Since Bowl is not subject to tax in N (the destination state), dock sales made to residents of N are treated as in-state sales of K (the origination state).

Sales Factor for State M

Sales to residents of M

$900,000

Sales factor: $900,000/$2,500,000 = 36.00%

Bowl’s salesperson has the authority to accept and approve sales to customers located in M. Accordingly, the activities of the salesperson exceed that immune under Public Law 86-272, thereby creating nexus. Bowl is subject to tax in M.

Sales Factor for State N

Since Bowl’s connection with State N is limited to residents of that state taking delivery of Bowl’s product at Bowl’s shipping dock after placing an online order, insufficient nexus is established to subject Bowl to taxation in N. Accordingly, a zero sales factor is created for N.

Nonetheless, since K has adopted a throwback provision, sales to residents of N are attributed to K, and they are used in determining the K sales factor. Bowl has no “nowhere sales.”

1924. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #9
Mercy Corporation, headquartered in F, sells wireless computer devices, including keyboards and bar code readers. Mercy’s degree of operations is sufficient to establish nexus only in E and F. Determine its sales factor in those states.

State E applies a throwback rule to sales, while State F does not. State G has not adopted an income tax to date. Mercy reported the following sales for the year. All of the goods were shipped from Mercy’s F manufacturing facilities.

Customer

Customer’s Location

This Year’s Sales

NorCo

E

$ 60,000,000

Tools, Inc.

F

20,000,000

UniBell

G

50,000,000

U.S. Department of Defense

All 50 U.S. States

20,000,000

Total

$150,000,000

1925. CHAPTER 16—MULTISTATE CORPORATE TAXATION Question PR #10
Garcia Corporation is subject to tax in States G, H, and I. Garcia’s compensation expense includes the following.

State G

State H

State I

Total

Salaries and wages for nonofficers

$200,000

$500,000

$500,000

$1,200,000

Officers’ salaries

–0–

–0–

800,000

800,000

Officers’ salaries are included in the payroll factor for G and H, but not for I. Compute Garcia’s payroll factors for G, H, and I.