California's New Approach to Apportionment Is a Throwback to the Old

Hopkins, Peter Desmond M., The CPA Journal

The California Franchise Tax Board (FTB) has proposed an amendment to the California Code of Regulations (18 Prop. C.C.R. section 25100.5) that would revive a long-standing corporate income apportionment rule that had been in effect for more than 20 years until it was struck down by a board of equalization decision in 1988. The amendment may also signal a refund opportunity for some groups filing California corporate returns.

General Framework of the Unitary Concept

A member of a group of two or more related corporations is generally required to file a combined California return if the group meets the definition of a "unitary group." A unitary group exists where the …

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Publication information: Article title: California's New Approach to Apportionment Is a Throwback to the Old. Contributors: Hopkins, Peter Desmond M. - Author. Magazine title: The CPA Journal. Volume: 70. Issue: 5 Publication date: May 2000. Page number: 64+. © New York State Society of Certified Public Accountants Feb 2009. Provided by ProQuest LLC. All Rights Reserved.

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