Answered step by step
Verified Expert Solution
Question
1 Approved Answer
Please help me find the numerators in each states using the three exhibits. To From cc Facts Transportation and Services, Inc (T&S) is a third
Please help me find the numerators in each states using the three exhibits.
To From cc Facts Transportation and Services, Inc (\"T&S\") is a third party logistics provider that caters to automotive manufactures in the United States and Canada. Auto Manufacturer 1 (A&M1) and Auto Manufacturer 2 (A&M2) are the customers of T&S. Both A&M1 and A&M2 are domiciled in California. T&S has contracts with A&M1 and A&M2 to process and transport vehicles from ports or factories to dealer locations within the United States. Pursuant to these contracts T&S performs (1) vehicle transportation and (2) vehicle processing. Vehicle Transportation Vehicle Transportation involves transporting a vehicle from the port or factory to a dealer location via rail and/or truck from the processing location to dealer locations. Fees per vehicle transported range from $96 to $2,113 based on where it is shipped from and where it is shipped to. T&S engages independent trucking subcontractors that perform all transportation services. Vehicle Processing Vehicle processing involves preparing a car for shipment, including: general labor, inspection, shuttling, car wash, add fuel, literature throw in, and final inspection. Vehicle processing fees per vehicle differ based on the location the processing is conducted. T&S engages independent subcontractors that conduct vehicle processing in California, as well as other states. With the exception of the processing done in Texas, all the income producing activity associated to the processing of any one vehicle is incurred exclusively in one state. The processing price in the contract for cars processed through the Texas \"ports\" is significantly more than the price for cars in other ports. This price difference is due to the fact that the Texas processing price includes the service of transporting via rail the car from the port (in San Diego and Portland) to the inland port in Texas. California Activities T&S contracts with third party processing companies to perform port processing services on its behalf in Port Hueneme, CA and Richmond, CA. T&S contracts with third party trucking companies to transport the automobile from CA ports to both California dealers and non-California dealers and from non-California ports (and factory locations) to both California dealers and non-California dealers. Of the vehicles that are delivered to California port locations, there are vehicles that are fully processed within a California port and there are also vehicles that are transported to Texas for processing. Vehicles that are processed in the Texas inland processing locations (Midlothian, TX for A&M2 and Alliance-Fort Worth, TX for A&M1) are first shipped from a foreign location to Port Hueneme, CA. 1 From Port Hueneme, the vehicles are transported by rail to a Texas inland processing location. California Elections For the tax year ending 12/31/2012 T&S will elect under California Revenue and Taxation Code (CRTC) section 25128.5 to use the single sales factor apportionment in California. Texas Inland Processing The income producing activities associated to the Texas inland vehicle process fees are performed by T&S and its subcontractors in more than one state. The following charts list: (1) each income producing activity associated to the Texas Inland Processing Fee, (2) the state(s) in which each activity is performed, and (3) the percentage of the total costs associated to each activity. The percentages are for the year ended December 31, 2010. Note that the rates were slightly different for other years involved, but it is not material for the purpose of our analysis. 1 The transportation of the vehicles from the foreign location to the U.S. port is not part of T&S's contract and is not performed by T&S. A&M1 and A&M2 arrange for that transportation with another transportation company. A&M2- Midlothian Inland Processing A&M1- Alliance Inland Processing (for Bi-Level Rail Transportation) A&M1- Alliance Inland Processing (for Tri-Level Rail Transportation) Georgia Activities T&S has contracted with third parties to perform port processing services on its behalf in the cities of Brunswick, Georgia and Westpoint, Georgia. T&S has contracted with third party trucking companies to transport the automobiles from GA ports to both Georgia dealers and non-Georgia dealers and from non-Georgia ports to both Georgia dealers and nonGeorgia dealers. Oregon Activities T&S has contracted with third parties to perform port processing services on its behalf in Portland, OR. T&S has contracted with third party trucking companies to transport the automobiles from the Portland, Oregon port to both Oregon dealers and non-Oregon dealers and from non-Oregon ports to both Oregon dealers and non-Oregon dealers. Issue Consider the following revenue streams: Vehicle Transportation Fees Vehicles transported from an in state port to an out of state dealer Vehicles transported from an out of state port to an in state dealer Vehicles transported from an in state port to an in state dealer Vehicles transported from an out of state port to an out of state dealer. Vehicle Processing Fees Vehicles processed in state and delivered to an in state dealer Vehicles processed in state and delivered to an out of state dealer Vehicles processed out of state and delivered to an in state dealer Vehicles processed out of state and delivered to an out of state dealer California For years 2010 through 2013, how should T&S source its revenue for California sales factor purposes? In other words, which revenue streams, or portions thereof, should be included in the California sales apportionment factor numerator? And how would they go about determining this? Texas For years 2013, how should T&S source its revenue for Texas sales factor purposes? In other words, which revenue streams, or portions thereof, should be included in the Texas sales apportionment factor numerator? And how would they go about determining this? Oregon For years 2013, how should T&S source its revenue for Oregon sales factor purposes? In other words, which revenue streams, or portions thereof, should be included in the Oregon sales apportionment factor numerator? And how would they go about determining this? Georgia For years 2013, how should T&S source its revenue for Georgia sales factor purposes? In other words, which revenue streams, or portions thereof, should be included in the Georgia sales apportionment factor numerator? And how would they go about determining thisStep by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started