Article: Implementing state corporate income taxes in the digital age.

INTRODUCTION

To date most discussion of state taxation of electronic commerce has focused on the sales and use tax.(1) There are, however, also interesting and important issues involving application of the state corporate income tax to income from electronic commerce.(2) This paper reviews some of these.(3) It begins with a brief discussion of the conceptual foundation of state corporate income taxes. The second section considers the basic structure of state corporate income taxes--the choice between separate reporting and formula apportionment, the role of unitary combination, and the choice of apportionment factors. The third and fourth sections discuss two key ...

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