Tax laws require state taxation of corporate income to accurately and fairly reflect a taxpayer’s income-generating activities in the taxing state. Brattle has performed detailed analyses to determine whether state apportionment formulas proportionately attribute income and weigh economic factors related to a taxpayer’s in-state business activity. We have also recommended alternative apportionment approaches that would be economically appropriate given case-specific facts. We have conducted unitary analyses and transfer pricing analyses in this context.

Representative Engagements:

  • Provided support for a client for its subsidiary capital structure in Massachusetts and performed a unitary-type analysis.
  • Performed apportionment analysis for a client on its business in twenty states based on personnel, payroll, and other factors.
  • Presented to state tax authorities.