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


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  • Charles E. McLure, Jr.
  • Walter Hellerstein


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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Bibliographic Info

Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 9060.

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Date of creation: Jul 2002
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Publication status: published as McLure Jr., Charles E. and Walter Hellerstein. Tax Notes, Vol. 96, No. 11 (September 9, 2002), pp. 1513-1520
Handle: RePEc:nbr:nberwo:9060

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Cited by:
  1. Harry Grubert, 2004. "Tax Credits, Source Rules, Trade and Electronic Commerce: Behavioral Margins and the Design of International Tax Systems," CESifo Working Paper Series 1366, CESifo Group Munich.
  2. Timothy J. Bartik, 2004. "Evaluating the Impacts of Local Economic Development Policies on Local Economic Outcomes: What Has Been Done and What Is Doable?," Book chapters authored by Upjohn Institute researchers, W.E. Upjohn Institute for Employment Research, in: Evaluating Local Economic and Employment Development: How to Access Waht Works Among Programmes and Policies, pages 113-142 W.E. Upjohn Institute for Employment Research.


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