TITLE

The Complete Liquidation Exception and Other Recent Illinois Business Income Developments

AUTHOR(S)
Stocker, Brian
PUB. DATE
September 2005
SOURCE
Journal of State Taxation;Fall2005, Vol. 24 Issue 2, p11
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
This article discusses the effect of the Illinois Appellate Court decision in the case of Blessing/White Inc. on the liquidation of a unitary subsidiary as business income for tax purposes. It is argued that the modified functional test proposed in the Blessing/White case should not be applicable to the liquidation of a unitary subsidiary if the unitary business still exists after the liquidation. Related Illinois statutory modifications and how they affect a complete liquidation transaction are discussed.
ACCESSION #
19527141

 

Related Articles

  • United States. Goldsworth, John // Accountancy;Mar1988, Vol. 101 Issue 1135, p54 

    This article reports that the British Government has been urged to take action against U.S. companies with British-based subsidiaries unless U.S. states abandon unitary tax. A House of Commons motion called on the British government to impose penalties under Financial Act, which empowers the...

  • International Taxation. Alpert, Gideon; Cummings, Jack; Rowe, Kevin; Tanenbaum, Edward // Corporate Business Taxation Monthly;Nov2004, Vol. 6 Issue 2, p21 

    The article focuses on reorganization ruling of Code Section 304 related to international taxation. Revenue Ruling 2004-83 holds that the sale of one subsidiary to another subsidiary followed by the liquidation of the purchased subsidiary as part of an integrated plan qualifies as a...

  • MANEUVERING LIQUID ASSETS IN A MULTI-NATIONAL COMPANY: FORMULATION AND DETERMINISTIC SOLUTION PROCEDURES. Rutenberg, David P. // Management Science;Jun70, Vol. 16 Issue 10, pB-671 

    Over a finite horizon each national subsidiary of a multi-national company can be forecast to be a net source or sink of funds. Each of these subsidiaries in each year is considered to be the node of a network; funds flow along the directed arcs connecting the nodes. Liquid assets carried by the...

  • It's Not a Duck Just Because it Quacks: Pennsylvania Court Rules That a Deemed Asset Liquidation Election Under IRC Section 338(h)(10) is Not a "Liquidation" Giving Rise to Nonbusiness Income. Perry, Gregg // Venulex Legal Summaries;2002 Q1, p1 

    The article focuses on the decision of a Pennsylvania court regarding the Canteen Corporation versus Commonwealth that was filed on February 8, 2002. The court ruled that an election under Internal Revenue Code Section 338(h)(10) to treat the accompanying transfer of assets in a subsidiary...

  • Citrin Cooperman Corner. SEIDEN, DAVID // Westchester County Business Journal;4/1/2013, Vol. 49 Issue 13, p5 

    The author explains how an individual is required to pay state income taxes, and discusses the difference between a resident and a nonresident of a state.

  • Washington Voters to Decide on State Income Tax in November. Saskal, Rich // Bond Buyer;7/19/2010, Vol. 373 Issue 33351, p7 

    The article reports that the implementation of state income tax will be decided by Washington voters in November 2010.

  • An Empirical Analysis of Unitary Apportionment. Hreha, Karen S.; Silhan, Peter A. // Journal of the American Taxation Association;Fall86, Vol. 8 Issue 1, p7 

    Much debate has focused on the issue of unitary apportionment. Under the current system, a multistate corporation which operates as a unitary business must allocate its income by averaging three proportions: in-state sates to total sales, in-state property to total property, and in-state payroll...

  • Apportionment of Multijurisdictional Corporate Income. Schmidt, Dennis R. // Journal of the American Taxation Association;Fall86, Vol. 8 Issue 1, p19 

    This study focuses on the issue of unitary income allocation and presents the results of an empirical analysis of formulary apportionment. The reported values of income, property, payroll, and sales for 252 large corporations are analyzed using multiple regression and error metric techniques....

  • THE IMPACT OF STATE LOTTERIES ON STATE TAX REVENUES. Fink, Stephen C.; Marco, Alan C.; Rork, Jonathan C. // Proceedings of the Annual Conference on Taxation;2002, p391 

    Examines the impact of state lotteries on state tax revenue in New Hampshire. Increase in revenue; Absence of tax revenue's response to lottery revenue; Assertion that decrease in sales tax revenue are offset by increase in corporate income tax revenues.

Share

Read the Article

Courtesy of VIRGINIA BEACH PUBLIC LIBRARY AND SYSTEM

Sorry, but this item is not currently available from your library.

Try another library?
Sign out of this library

Other Topics