Plaintiff reasoned that, because the economic loss rule precluded her from suing the Fabre defendants in tort, it was improper and unfair for the defendant general contractor to decrease its percentage of fault by
apportioning fault to these persons and entities.
The current method of
apportioning seats in the House of Representatives of the United States, the so-called "method of equal proportions," does not even aim to make the populations of congressional districts as equal as possible.
The unitary business principle holds that the local tax base is calculated by first defining the scope of the unitary business of which the taxed enterprise's activities in the taxing jurisdiction form one part, and then
apportioning the total income of the unitary business between the taxing jurisdiction and the rest of the world based on a formula "taking into account objective measures of the corporation's activities within and without the jurisdiction." Container Corp.
861 regulations in allocating and
apportioning deductions to DPGR.
For example, assume that in Example 25, X has most of its property and payroll in states B and C, most its sales in state A, and that all three states follow the same three-factor formula method in
apportioning net income.
Nevertheless, the FTB balks at
apportioning the credit.
* Family law/marital dissolution cases, which deal not only with the necessary financial issues, such as determining child support and alimony and tracing and
apportioning assets, but also the heartrending psychological trauma the involved parties experience, which no law or business school can prepare the CPA witness for.
The FTC limit is based on foreign-source taxable income, which is the amount after allocating and
apportioning deductions.
The in-state tax base is calculated by first defining the scope of the unitary business, of which the taxed enterprise's activities in the taxing state form one part, and then
apportioning the total income of the unitary business between the taxing state and other jurisdictions based on a formula taking into account objective measures of the corporation's activities within and without the jurisdiction.
1.861-9T(g)-(i), a taxpayer may elect to value assets on the basis of tax book value or fair market value (FMV), or on an alternative tax book value method, when allocating and
apportioning interest expense.
Department of the Treasury and Internal Revenue Service issued temporary and proposed regulations under section 861 of the Internal Revenue Code, relating to the use of an alternative tax book value method for allocating and
apportioning interest expense.
1.904-5(c) and 1.954-1(c) provide the basic rules for allocating and
apportioning a controlled foreign corporation's (CFC's) expenses.
