The defendant, Nadeau, pleaded the culpability of nonparties Camus/DEK (the developer) and Webster Bank (Millette's lender) as an affirmative defense for the purpose of apportioning
fault to them under Fabre and F.S.
The current total number of seats (435) in the House of Representatives of the United States, adopted in 1911, and the method of apportioning
them, adopted in 1929, lead to a larger population variation between the largest and smallest districts of representatives than is possible under an alternative method.
Rather than imposing their property taxes on the value of the iron and timbers physically located within their borders, the States moved toward valuing the entire business enterprise and devised a system for apportioning
that value among the various States based on factors such as the ratio of miles of track in the State to the miles of track everywhere.
199, the taxpayer must be consistent with respect to the method of allocating and apportioning
However, the calculation for apportioning
business income can be different for corporations and nonresident individuals under identical facts and circumstances.
1.199-1 to -8, which expand on the initial guidance offered in Notice 2005-14 by clarifying and providing additional instruction on a number of critical issues, including the rules for allocating and apportioning
income and expenses in computing the base amount available for the Sec.
To determine its section 199 deduction for the taxable year, a partner or shareholder aggregates its distributive share of such items with those items it incurs outside the pass-through entity for purposes of allocating and apportioning
deductions to DPGR and computing its QPAI.
assets between deferred and nondeferred accounts.
131.20 provides guidance for allocating and apportioning
pension and deferred compensation amounts received by nonresident individuals and says that such amounts should be apportioned by using the individual's average percentage of days worked in New York to total days worked each year for the current and the three immediately preceding tax years.
LD 1691, Laws 2005, increases the tax imposed on some multistate corporations by requiring that the unitary group first determine the Maine tax on 100% of its income and then apportioning
the tax to Maine, and cancelled Maine's membership in the Multistate Tax Commission.
[section] 1.861-9T(g) for purposes of allocating and apportioning
interest expense under section 864(e).
IRC section 863(b)(2) and regulations section 1.863-3(b)2) provide rules, in the form of examples, for apportioning
States A, B, and C each determine X's income subject to tax within their states by adjusting X's federal taxable income, and apportioning
such income on the basis of the relative amounts of X's payroll, property, and sales.
Under California's unitary system, the in-state tax base is calculated by first defining the scope of the unitary business, of which the taxed enterprise's activities in the taxing state form one part, and then apportioning
the total income and expenses of the unitary business between the taxing state and other jurisdictions based on a formula that takes into account objective measures of the corporation's activities within and without the jurisdiction.
partner to double-count the foreign-source assets when apportioning
interest expense, because the loan would be reflected in the foreign-source asset basis twice.