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XYZ Corp realized $1.5 million of taxable income from the sales of its products

ID: 2448339 • Letter: X

Question

XYZ Corp realized $1.5 million of taxable income from the sales of its products in State A and State B. XYZ is taxable by both states, and its gross sales, payroll, and property are allocated between the states as follows:

State A State B Total

Gross Sales $2,000,000 $2,000,000 $4,000,000

Payroll 1,500,000 0 1,500,000

Property 2,500,000 0 2,500,000

Income Tax Rate 10% 5%   

State A allows a company to elect either an equal weighted three factor apportionment method or a double weighted sales factor in a three factor apportionment method. Which method will allow XYZ to apportion the smallest amount of income to State A?

Explanation / Answer

SOLUTION :

equal weighted three factor apportionment method

(2000000/4000000)

0.5

(1500000/1500000)

1

(2500000/2500000)

1

TOTAL

2.5

AVERAGE (2.5/3)

          0.83

TAXABLE INCOME

1500000

TAXABLE INCOME APPORTIONED TO STATE A

1250000

TAX AT 10%

125000

double weighted sales factor in a three factor apportionment method.

(2000000/4000000)*2

1

(1500000/1500000)

1

(2500000/2500000)

1

TOTAL

3

AVERAGE (3/4)

          0.75

TAXABLE INCOME

1500000

TAXABLE INCOME APPORTIONED TO STATE A

1125000

TAX AT 10%

112500

Conclusion : A double weighted sales factor in a three factor apportionment method will allow XYZ to apportion the smallest amount of income to State A.

equal weighted three factor apportionment method

(2000000/4000000)

0.5

(1500000/1500000)

1

(2500000/2500000)

1

TOTAL

2.5

AVERAGE (2.5/3)

          0.83

TAXABLE INCOME

1500000

TAXABLE INCOME APPORTIONED TO STATE A

1250000

TAX AT 10%

125000

double weighted sales factor in a three factor apportionment method.

(2000000/4000000)*2

1

(1500000/1500000)

1

(2500000/2500000)

1

TOTAL

3

AVERAGE (3/4)

          0.75

TAXABLE INCOME

1500000

TAXABLE INCOME APPORTIONED TO STATE A

1125000

TAX AT 10%

112500

Conclusion : A double weighted sales factor in a three factor apportionment method will allow XYZ to apportion the smallest amount of income to State A.