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Corporations other than Section 38 manufacturers or mutual fund service corporations are required to apportion their net income as follows: sales factor 50%, property factor 25%, payroll factor 25%.
Using the UDITPA, or three-factor formula, a state accounts for the percentage of a companys payroll, property, and sales that were based in the state and then divides that number by 3 to come up with the percentage of income the state can tax.
Apportionment is the determination of the percentage of a business profits subject to a given jurisdictions corporate income or other business taxes. U.S. states apportion business profits based on some combination of the percentage of company property, payroll, and sales located within their borders.
What is the standard Massachusetts apportionment formula? Corporations that have taxable income from business activity both in and outside Massachusetts must assign income to Massachusetts using a three-factor apportionment formula consisting of a property factor, a payroll factor, and a double weighted sales factor.
For Massachusetts tax purposes, a taxpayers income subject to apportionment is its entire income derived from its related business activities within and outside of Massachusetts not including any allocable items of income that either are or are not subject to the tax jurisdiction of Massachusetts.
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