State Income Taxation of Mercantile and Manufacturing Corporations

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Committee Serial No. 20. Considers state corporate income tax procedure impact on multistate manufacturing and mercantile corporations. Includes discussion of possible adoption of uniform state taxation standards and the possible taxation of interstate business income of non-resident corporations.
 

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Page 642 - It is the power to regulate ; that is, to prescribe the rule by which commerce is to be governed. This power, like all others vested in Congress, is complete in itself, may be exercised to its utmost extent, and acknowledges no limitations other 5 than are prescribed in the Constitution.
Page 506 - permanent establishment" shall be deemed not to include: a) the use of facilities solely for the purpose of storage. display or delivery of goods or merchandise belonging to the enterprise...
Page 128 - It is evident that the criteria by which we mark the boundary line between those activities which justify the subjection of a corporation to suit, and those which do not, cannot be simply mechanical or quantitative. The test is not merely, as has sometimes been suggested, whether the activity, which the corporation has seen fit to procure through its agents in another state, is a little more or a little less.
Page 405 - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests...
Page 143 - I have a couple of questions I would like to ask you with respect to this.
Page 238 - State; or (ii) the base of operations or place from which such service is directed. or controlled is not in any State in which some part of the service is performed but the individual's residence is in this State.
Page 128 - Whether due process is satisfied must depend rather upon the quality and nature of the activity in relation to the fair and orderly administration of the laws which it was the purpose of the due process clause to insure.
Page 487 - ... the base of operations or the place from which the service is directed or controlled is not in any state in which some part of the service is performed, but the individual's residence is in this state.
Page 406 - Secretary or his delegate may distribute, apportion, or allocate gross Income, deductions, credits, or allowances between or among such organizations, trades, or businesses. if he determines that such distribution, apportionment, or allocation is necessary In order to prevent evasion of taxes or clearly to reflect the Income of any of such organizations, trades, or businesses.
Page 435 - ... the solicitation of orders by such person, or his representative, in such State for sales of tangible personal property, which orders are sent outside the State for approval or rejection, and, if approved, are filled by shipment or delivery from a point outside the State...

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