State Taxation of Foreign Source Income Through Worldwide Combined Reporting

State Taxation of Foreign Source Income Through Worldwide Combined Reporting PDF

Author: Thomas Pearson

Publisher:

Published: 2023

Total Pages: 0

ISBN-13:

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This Note considered whether a state can tax the worldwide combined income of a unitary business of a United States parent corporation and foreign subsidiaries. The primary alternative to worldwide combined reporting is the federal government's arm's length method of taxing foreign source income. This Note considered the effect of the 1983 Supreme Court decision, Container Corporation of America v. Franchise Tax Board.