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International And Interstate Approaches To Taxing Business Income, David M. Hudson, Daniel C. Turner

Northwestern Journal of International Law & Business

In the United States, many states have sought the objective of uni- formity by enacting the Uniform Division of Income for Tax Purposes Act (UDITPA). In addition, many of those same states have entered into the Multistate Tax Compact (MTC). The salutary objective of both the UDITPA and the MTC is to provide uniform rules for the allocation and apportionment of income, in order to facilitate both compliance and enforcement, as well as to reduce the likelihood of double taxation. The promised uniformity, however, has been at the same time both illusive and elusive. Experience with the UDITPA and the …