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Colbert Manufacturing was created in 1988. It manufactures consumer durable goods, such as dinnerware and kitchen gadgets for Paul Hollywood’s US Based kitchenware line. Colbert was incorporated in the state of South California (SC); the corporate manufacturing operations, product distribution center, warehouses, and executive headquarters of the entity still are located there. The industry is extremely profitable, with new product opportunities popping up regularly as the US population gathers interest in “nesting” activities such as home theaters and elaborate meal preparation
at home, especially during and after COVID.
Colbert makes no direct sales outside of the US, and its customers are located strictly in South California and the adjacent state of North Mexico (NM). SC and NM both are members of the Multistate Tax Commission
, and they have adopted all of the MTC rules and regulations. Further, both states have adopted verbatim the UDITPA
as state law. Both SC and NM employ a three-factor apportionment formula, with equal weights for sales, property, and payroll. Neither state applies the unitary method of apportioning state taxable incomes.
The Colbert controller forwards to you the following information ($K).
Total taxable income, all apportionable
20,000
SC tax rate, state corporate income tax
10%
NM tax rate, state corporate income tax
3%
Asset holdings used in the business operations, business payroll, and sales data totaled the following amounts ($K). Asset-related amounts were reported by the Colbert controller properly using book historical costs, net of book depreciation. Colbert uses the accrual method, and the calendar year, for book and tax purposes. No significant book-tax differences exist for the current tax year.
Sales
Payroll
Property
South California
30,000
8,000
10,000
North Mexico
10,000
2,500
100
Total
40,000
10,500
10,100
1. Using the data above, compute Colbert’s SC and NM tax liabilities for the year.
2. Use the facts as above, except assume that NM uses a sales-factor-only apportionment formula.
3. Return to the original facts, in which both SC and NM use an equal three-factor apportionment formula. You want to propose to Colbert management that the company move its product distribution center and warehouse operations from SC to NM. This would entail the transfer from SC to NM of $4,000,000 of costs in the property factor and $1,000,000 of costs in the payroll factor. Revise your analysis to indicate the resulting state income tax savings that would result from this plan. Ignore all nontax considerations of this decision, as well as any moving and transition costs that would be incurred.
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