Tax laws require state taxation of corporate income to accurately and fairly reflect a taxpayer’s income-generating activities in the taxing state. Brattle has performed detailed analyses to determine whether state apportionment formulas proportionately attribute income and weigh economic factors related to a taxpayer’s in-state business activity. We have also recommended alternative apportionment approaches that would be economically appropriate given case-specific facts. We have conducted unitary analyses and transfer pricing analyses in this context.
- Provided support for a client for its subsidiary capital structure in Massachusetts and performed a unitary-type analysis.
- Performed apportionment analysis for a client on its business in twenty states based on personnel, payroll, and other factors.
- Presented to state tax authorities.
Complex business and legal matters require intellectually honest and analytically rigorous solutions that are thoughtfully developed and clearly communicated. We apply economic and finance principles with uncompromising quality to achieve clarity in the face of complexity. Independent analysis, responsive execution, and compelling presentation. That’s Brattle. That’s the Power of Economics.