Should the States Return to Worldwide Combined Reporting?

Authors

Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow

Document Type

Article

Publication Date

4-2025

Abstract

On February 20 the Institute on Taxation and Economic Policy (ITEP) released a report on the revenue implications of states adopting worldwide combined reporting (WWCR). WWCR refers to a method of taxation that several states (for example, California) applied from the 1970s to the 1990s. Under WWCR, the state takes the entire worldwide profit of a multinational operating in the state and multiplies it by a formula that traditionally combines payroll, tangible assets, and sales in the state divided by worldwide payroll, assets, and sales. The result is the amount of profit taxable in that state.

Comments

Reprinted with the permission of Tax Analysts.

Recommended Citation

Avi-Yonah, Reuven S. "Should the States Return to Worldwide Combined Reporting?" Tax Notes International 118, no. 15 (2025): 245-250.