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Attribution Of A Multinational Corporation's Net Income: The Position Of Unitary States Regarding Combined Reporting, William D. Dexter
Attribution Of A Multinational Corporation's Net Income: The Position Of Unitary States Regarding Combined Reporting, William D. Dexter
Vanderbilt Journal of Transnational Law
A complex and controversial aspect of state taxation of business income involves the attribution of a multinational corporation's (MNC's) net income. This Article examines the nature and scope of the controversy that stems from the conflicting views of states that promote a unitary taxation system, and MNCs as well as the Department of Treasury (Treasury) that oppose this position. Section IV illustrates why the unitary business principle is currently the only viable, fair, and feasible method available to the states for the geographical assignment of an MNC's net income. Section V analyzes the MNCs' arguments both against worldwide combined reporting …