Section 3 Eligibility for Allocation and Apportionment of Income

• Library: Tax Law 2009

No cases have yet addressed whether mere incorporation in a state other than Missouri, without any business activity or physical presence in that state and with no use of capital or labor in that other state, would support single-factor apportionment. Furthermore, regulations promulgated under Article IV of the Compact provide that if a corporation pays a minimal tax by reason of its organization under the laws of the state, but engages either in no business activity in the state or in activity...