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When the taxpayer operates in one or more unitary states:


A) Apportionment factors are computed on a group-wide basis.
B) The tax incentive of creating nexus in a low-tax state is enhanced.
C) The tax benefit of a passive investment subsidiary holding company is neutralized.
D) The use of a water's edge election should be considered.
E) All of the above are true.

F) C) and D)
G) A) and C)

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Roughly five percent of all taxes paid by businesses in the U.S. are to state, local, and municipal jurisdictions.

A) True
B) False

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State Q has adopted sales-factor-only apportionment for its corporate income tax. As a result, a (larger/smaller) percentage of an out­of­state corporation's income is assigned to tax in the state.

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Match each of the following terms with the appropriate description, in the state income tax formula. Apply the UDITPA rules in your responses. a. Addition modification b. Subtraction modification c. No modification -State-level NOL.

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Identify some state/local income tax issues facing pass-through entities such as S corporations, partnerships, and LLCs.

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-Does the owner have nexus with every s...

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Match each of the following events, considered independently, to its likely effect on WillCo's various apportionment factors. WillCo is based in Q and has customers in Q, R, and S. To this point, WillCo has not established nexus with S. More than one choice may be correct. a. No change in apportionment factors b. Q apportionment factor increases c. Q apportionment factor decreases d. R apportionment factor increases e. R apportionment factor decreases f. S apportionment factor increases g. S apportionment factor decreases -Q adopts a sales-only apportionment formula.

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Hendricks Corporation sells widgets in two states. State A levies a 9% effective tax rate, and State B levies a 3% rate. A and B have adopted sales-factor-only apportionment formulas. To reduce overall multistate income tax liabilities, Hendricks should:


A) Move its home office from B to A.
B) Remove all stored inventory from A.
C) Establish a personal training center in A.
D) Convert to employee status the independent contractors that it uses to sell widgets in A.

E) B) and D)
F) A) and B)

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The throwback rule requires that:


A) Sales of tangible personal property are attributed to the state where they originated, if the taxpayer is not taxable in the state of destination.
B) Sales of tangible personal property are attributed to the seller's state, even if the taxpayer is not taxable in the state of destination.
C) Sales of services are attributed to the state of commercial domicile.
D) Capital gain/loss is attributed to the state of commercial domicile.

E) A) and B)
F) A) and C)

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Typically, the state's payroll factor (does/does not) include the salaries and bonuses paid to its corporate executives.

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Match each of the following items with the appropriate description, in applying the P.L. 86-272 definition of solicitation. a. More than solicitation, creates nexus b. Solicitation only, no nexus created -Checking the customer's inventory to determine whether a reorder is needed.

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Match each of the following items with the appropriate description, in determining whether sales/use tax typically must be collected. a. Taxable b. Not taxable -Groceries purchased by a consumer and taken home for preparation there.

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A unitary business applies a combined apportionment formula, including data from operations of all of the affiliates.

A) True
B) False

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Match each of the following events, considered independently, to its likely effect on WillCo's various apportionment factors. WillCo is based in Q and has customers in Q, R, and S. To this point, WillCo has not established nexus with S. More than one choice may be correct. a. No change in apportionment factors b. Q apportionment factor increases c. Q apportionment factor decreases d. R apportionment factor increases e. R apportionment factor decreases f. S apportionment factor increases g. S apportionment factor decreases -R adopts an increase in its statutory corporate income tax rates.

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A(n) business operates in concert with its affiliated companies. As a result, the affiliates' data are included in the parent's apportionment computations.

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When the taxpayer has exposure to a capital stock tax:


A) The pricing of inventory sales should reflect no more than inflation increases.
B) Subsidiary operations should be funded through direct capital contributions.
C) Dividends should be paid regularly to a parent based in a low-tax state.
D) Expansions should be funded with retained earnings.

E) A) and D)
F) A) and B)

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The property factor includes land and buildings used for business purposes.

A) True
B) False

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General Corporation is taxable in a number of states. This year, General made a $100,000 sale from its A headquarters to an agency of the U.S. government. State A applies a throwback rule. In which state(s) will the sale be included in the sales factor numerator?


A) $0 in A.
B) $50,000 in A, with the balance exempted from other states' sales factors under the Colgate doctrine.
C) $100,000 in A.
D) In all of the states, according to the apportionment formulas of each, as the U.S. government is present in all states.

E) B) and C)
F) A) and B)

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State Q wants to increase its income tax collections, but politically it would be unwise to raise taxes on in-state individuals or businesses. Q currently follows all UDITPA rules and employs an equally weighted three-factor apportionment formula. Q allocates nonbusiness income amounts. Identify some changes to the income tax apportionment formula that would shift the scheduled income tax increases to out-of-state businesses.

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-Over-weighting the sales factor.
-Sale...

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Overall tax liabilities typically (increase/decrease) if the members of a unitary group begin to include affiliates that generate net operating losses.

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Most states' consumer sales taxes are paid by the final purchaser of the taxable asset.

A) True
B) False

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