Question
CompuCorp. delivers products to its customers via third-party common carriers (i.e. FedEx and UPS). CompuCorp. reported taxable income of $10M for its tax year ending
CompuCorp. delivers products to its customers via third-party common carriers (i.e. FedEx and UPS). CompuCorp. reported taxable income of $10M for its tax year ending December 31, 2021.
All of CompuCorps products include a one-year limited warranty for which there is no additional charge. The overwhelming majority of warranty-related issues are resolved via remote (online and telephone) technical assistance, or by simply sending the customer a replacement product. On rare occasions on-site repair may be advisable, in which case, CompuCorp. arranges for an independent third-party technician to visit the customer and address the issue.
Historically CompuCorp. did not file state corporate income tax returns in any state other than Arizona. This was based on the prior tax advisers understanding that the company was protected from state income tax liability under case law precedent (Quill Corp.) and federal statute (P.L. 86-272).
CompuCorp. had an additional sale of $20M (total sales now $220M) related to the sale/leaseback of its corporate offices. For purposes of this question, assume the sale of CompuCorp.s corporate offices is properly treated as business income.
There is no more information than this .. What I gave originally should have sufficed to calculate apportionment.
State | Formula (i.e. Factors/Components) | Overall Appt. % |
AZ | ||
CA | ||
FL |
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