Not Available for Download

Does Sales-Only Apportionment Violate International Trade Rules?

Posted: 6 Sep 2002  

Charles E. McLure Jr.

Stanford University - The Hoover Institution on War, Revolution and Peace; National Bureau of Economic Research (NBER)

Walter Hellerstein

University of Georgia School of Law

Abstract

There has been a pronounced change in the formulas states use to apportion the income of multistate corporations from one that placed equal weight on payroll, profits, and sales to one that places at least half the weight on sales, and eight states base apportionment solely on sales. This report, which is intended to stimulate further analysis and debate, rather than provide a definitive conclusion, suggests that sales-only apportionment may violate international trade rules that prohibit export sales.

Suggested Citation

McLure, Charles E. and Hellerstein, Walter, Does Sales-Only Apportionment Violate International Trade Rules?. Tax Notes, Vol. 96, No. 11, September 9, 2002. Available at SSRN: https://ssrn.com/abstract=328882

Charles E. McLure Jr. (Contact Author)

Stanford University - The Hoover Institution on War, Revolution and Peace ( email )

434 Galvez Hall, MC 6010
Stanford, CA 94305
United States
(415) 723-2657 (Phone)

National Bureau of Economic Research (NBER)

1050 Massachusetts Avenue
Cambridge, MA 02138
United States

Walter Hellerstein

University of Georgia School of Law ( email )

209 Hirsch Hall
Athens, GA 30602
(706) 542-5175 (Phone)
(706) 542-5556 (Fax)

Paper statistics

Abstract Views
1,242