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Formulary apportionment, also known as unitary taxation, is a method of splitting the total pre-tax profit earned (or loss incurred) ...
The courts have held that the requirement for fair apportionment may be met by apportioning between jurisdictions all business income of a corporation based on a formula using the particular corporation's details. [46] Many states use a three factor formula, averaging the ratios of property, payroll, and sales within the state to that overall.
The Apportionment Act 1870 (33 & 34 Vict. c. 35) extends to payments not made under any instrument in writing (section 2), but not to annual sums made payable in policies of insurance (section 6). Apportionment under the act can be excluded by express stipulation. [2] The apportionment created by this statute is "apportionment in respect of time."
A formulary is a list of pharmaceutical drugs, often decided upon by a group of people, for various reasons such as insurance coverage or use at a medical facility. [1] Traditionally, a formulary contained a collection of formulas for the compounding and testing of medication (a resource closer to what would be referred to as a pharmacopoeia ...
Uniform Apportionment of Tort Responsibility Act, a Uniform Act drafted by the National Conference of Commissioners on Uniform State Laws (NCCUSL) Formulary apportionment , a method of allocating corporate taxation between jurisdictions
A frequently-proposed [107] [108] alternative to arm's-length principle-based transfer pricing rules is formulary apportionment, under which corporate profits are allocated according to objective metrics of activity such as sales, employees, or fixed assets. Some countries (including Canada and the United States) allocate taxing rights among ...
Under US rules, apportionment of most deductions may be done based on relative sales, gross income (sales less cost of goods sold), space used, headcount, or some other rational and systematic basis. [49] The US has rules requiring that certain deductions be apportioned among all income on a formulary basis. These rules are quite complex.
Tax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes.