Notably, receipts from commercial activity do not include certain interest income; pension reversions; proceeds from the issuance of the taxpayer's own stock, options, warrants, puts, or calls, or from the sale of the taxpayer's treasury stock, contributions to capital, tax refunds, and other tax benefit recoveries and reimbursements; gifts or charitable contributions; rebates and transactions among members of a unitary group
; dividends; and distributive income received from a pass-through.
State tax haven legislation then requires taxpayers to include unitary foreign affiliates incorporated or operating in tax havens in the water's edge unitary group
or requires them to include the foreign affiliates' income in the group's tax base without permitting them to include those affiliates' apportionment data in the apportionment formula.
On the groups with the same orders of Sylow normalizers as the finite projective special unitary group
. Science in China, Ser A: Mathematics, v.
The supercharacters and superclasses of the unipotent unitary group
are indexed by labeled set partitions.
In the context of a unitary group
of corporations, each member of the unitary group
is treated as a separate entity for purposes of determining whether it is subject to tax in another state.
where [A.sup.*] denotes the transposed conjugate matrix of A and [E.sub.m] the unit matrix of the unitary group
The credits can be assigned to a member of the unitary group
, and in some cases, sold to third parties.
Fiscal year entities with affiliates will need to determine who will he the filing entity under the unitary group
filing requirements of the MBT.
"In New Hampshire, Wal-Mart would probably have to file as a unitary group
," said Maloney, "in which case, all entities would file a single return for business profit tax purposes."
States mandating unitary (combined) reporting do so by requiring a company to file a combined return with all of its affiliates that form a unitary group
. This allows the state to apply its apportionment formula to the combined income of a related group of corporations, even though some of the entities in the group might not otherwise be taxable in the state.