Treasury is reviewing the recently enacted tax law changes, including the new Marijuana Wholesale Tax. Developing clear and accurate information for tax stakeholders is our top priority. This guidance will be posted to our website in the coming weeks.
13. How is a unitary relationship determined?
A unitary relationship exists when a taxpayer has control over the entities and the entities have a flow of value between their various operations. Factors that establish a flow of value include:
- Economic realities
- Functional integration
- Centralized management
- Economies of scale
- Substantial mutual interdependence
These factors are not exhaustive or exclusive and the ability to elect combined apportionment will depend on the totality of the circumstances.