NATIONAL BUREAU OF ECONOMIC RESEARCH
NATIONAL BUREAU OF ECONOMIC RESEARCH

Does Sales-only Apportionment of Corporate Income Violate the GATT?

Charles E. McLure, Jr., Walter Hellerstein

NBER Working Paper No. 9060
Issued in July 2002
NBER Program(s):   ITI   PE

There has been a pronounced change in the formulas states use to apportion the income of multistate corporations from one that placed equal weight on payroll, profits, and sales to one that places at least half the weight on sales, and eight base apportionment solely on sales. This paper, which is intended to stimulate further analysis and debate, rather than provide a definitive conclusion, suggests that sales-only apportionment may violate the provisions of the General Agreement on Tariffs and Trade (the GATT) that prohibits export subsidies.

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Document Object Identifier (DOI): 10.3386/w9060

Published:

  • McLure Jr., Charles E. and Walter Hellerstein. Tax Notes, Vol. 96, No. 11 (September 9, 2002), pp. 1513-1520 ,
  • State Tax Notes, Vol. 25, No. 11 (September 9, 2002), pp. 779-86 ,
  • Tax Notes International, Vol. 27, No. 11 (September 9, 2002), pp. 1315-23 ,
  • CES/ifo Forum, Vol. 3, No.4 (Winter 2002), pp. 23-30.

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