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State Taxation of Foreign Source Income

State Taxation of Foreign Source Income
Author: United States. Congress. House. Committee on Ways and Means
Publisher:
Total Pages: 406
Release: 1980
Genre: Government publications
ISBN:

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U.S. Tax Treaties

U.S. Tax Treaties
Author: United States. Internal Revenue Service
Publisher:
Total Pages: 28
Release: 1990
Genre: Double taxation
ISBN:

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State Taxation of Foreign Source Income Through Worldwide Combined Reporting

State Taxation of Foreign Source Income Through Worldwide Combined Reporting
Author: Thomas Pearson
Publisher:
Total Pages: 0
Release: 2023
Genre:
ISBN:

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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.