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CALIFORNIA'S UNITARY METHOD OF ALLOCATING JURISDICTION TO TAX INCOME FROM MULTISTATE (OR NATION) BUSINESS: INTERNATIONAL APPLICATION AND IMPLICATIONS

CALIFORNIA'S UNITARY METHOD OF ALLOCATING JURISDICTION TO TAX INCOME FROM MULTISTATE (OR NATION)... Part III ' INTERNATIONAL APPLICATION AND IMPLICATIONS: CALIFORNIA'S UNITARY METHOD AND THE REALIZATION OF NEUTRALITY OF TAXATION IN RESPECT OF INVEST- MENT DECISIONS. When calculating the taxable profits of a branch or subsidiary of a multinational enterprise, most nations apply the separate entity accounting approach. Applying an alternative system based upon an appropriate share of the worldwide profits of the taxpayer, or the group to which it belongs, presents several issues. First, every nation must agree on the proper method of assessing worldwide profits of a multinational enter- prise; and second, a method of allocating a proper portion of the income to the proper country. As each of the states that use the unitary approach in the United States require, the proper method of calculating taxable income should be done according to the tax laws of the assessing country and translating the taxpayer's account into that nation's currency. Although restating the worldwide profits of a multinational group in accordance with the laws and in the currencies of every nation that the group operates is an enormous undertaking; the other alternative is the establishment of a unified worldwide system coordinated by an interna- tional body based upon the Multistate http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png Tilburg Law Review Brill

CALIFORNIA'S UNITARY METHOD OF ALLOCATING JURISDICTION TO TAX INCOME FROM MULTISTATE (OR NATION) BUSINESS: INTERNATIONAL APPLICATION AND IMPLICATIONS

Tilburg Law Review , Volume 6 (4): 355 – Jan 1, 1997

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Publisher
Brill
Copyright
© Koninklijke Brill NV, Leiden, The Netherlands
ISSN
2211-0046
eISSN
2211-2596
DOI
10.1163/221125997X00020
Publisher site
See Article on Publisher Site

Abstract

Part III ' INTERNATIONAL APPLICATION AND IMPLICATIONS: CALIFORNIA'S UNITARY METHOD AND THE REALIZATION OF NEUTRALITY OF TAXATION IN RESPECT OF INVEST- MENT DECISIONS. When calculating the taxable profits of a branch or subsidiary of a multinational enterprise, most nations apply the separate entity accounting approach. Applying an alternative system based upon an appropriate share of the worldwide profits of the taxpayer, or the group to which it belongs, presents several issues. First, every nation must agree on the proper method of assessing worldwide profits of a multinational enter- prise; and second, a method of allocating a proper portion of the income to the proper country. As each of the states that use the unitary approach in the United States require, the proper method of calculating taxable income should be done according to the tax laws of the assessing country and translating the taxpayer's account into that nation's currency. Although restating the worldwide profits of a multinational group in accordance with the laws and in the currencies of every nation that the group operates is an enormous undertaking; the other alternative is the establishment of a unified worldwide system coordinated by an interna- tional body based upon the Multistate

Journal

Tilburg Law ReviewBrill

Published: Jan 1, 1997

There are no references for this article.