State Income Taxation of Multijurisdictional Corporations: Reflections on <em>Mobil, Exxon</em>, and H.R. 5076

Hellerstein, Walter

Journal: Michigan Law Review

Volume: 79

First Page: 113

Year: 1980

Bluebook Citation: 79 MICH. L. REV. 113 (1980)

Author: Walter Hellerstein: all 25 publications


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Abstract

The purpose of this Article is twofold: first, to analyze the Mobil and Exxon decisions; second, to consider the congressional reaction they may engender. Because the terrain that this Article covers may be unfamiliar to some readers, a few further words of introduction may be appropriate. Taken together, the Mobil and Exxon decisions dealt with the three methods of dividing a multijurisdictional corporation's income among the states - specific allocation, separate accounting and apportionment by formula. Each method provides a different solution to the problem of determining the portion of the income of multistate businesses that should be taxable by any one state.

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