Section 29 Multiple Businesses of a Single Taxpayer

• Library: Tax Law 2009

The business income of each trade or business of the taxpayer is separately apportioned. 12 C.S.R. § 10-2.075(4) and (65). Whether a taxpayer is engaged in a single unitary trade or business or multiple businesses is a factual determination, but the regulations incorporate a strong bias toward a finding of a single unitary trade or business. In general, a taxpayer is deemed to be in a single business “if there is evidence to indicate that the segments under consideration are integrated with, dependent upon...