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  • adj

Synonyms for apportionable

capable of being distributed

References in periodicals archive ?
Similarly, the term "non-business income" is changed to "non-apportionable income" and defined as "all income other than apportionable income" (Multistate Tax Compact, Art.
It could be argued, therefore, the court in D'Amario already decided, as an unstated matter of law, that enhanced injuries have to be apportionable by their very nature.
A participating group of corporations would calculate apportionable income under the income tax rules of the Member State where the parent is resident (provided that Member State participates), including those pertaining to consolidation and cross-border offsetting of losses.
The definition of "direct tax" had to contract with the adoption of the Constitution, however, because some taxes ceased to be apportionable.
That disconnect suggests the need for a reassessment that should begin by examining the ACC conferees' recommendation to add DA as a third apportionable mission category.
all income that is apportionable under the Constitution of the United States and is not allocated under the laws of this state, including but not limited to: (A) income related to the operation of the taxpayer's trade or business; or (B) income from tangible [and] intangible property if the acquisition, management, employment, development, or disposition of the property is, or was, related to, or part of, the operation of the taxpayer's trade or business.
223) Thus, for these classes of businesses, there will be many instances in which they have in-state sales and, therefore, income apportionable to a state under the state's general apportionment formula, but are nevertheless nontaxable.
2) The Supreme Court's early gutting of the Clauses in Hylton, with dicta limiting the category of "direct taxes" to easily apportionable taxes and, more specifically, to capitation and real-estate taxes, was wrong.
The term "nonbusiness income" does not include income from tangible and intangible property if the acquisition, management, and disposition of the property constitute integral parts of the taxpayer's regular trade or business operations, or any amounts which could be included in apportionable income without violating the due process clause of the United States Constitution.
353) If the legislature has seen fit to declare that joint liability is to be especially preserved in environmental tort litigation, a court will be reluctant to conclude that the harm is apportionable and therefore not subject to joint liability.
If the election is effective for both states' purposes, the transaction generates gain from the deemed sale of the target corporation's assets, which is more likely to be business income (218) apportionable to the state in which the business is operated (here, State X).
By making this recommendation, the committee stated that the adjustment more accurately reflects the reality of apportionable income and reduces the likelihood that the apportionment formula will produce distortion.
On October 26, 2012, TEI filed the following brief amicus curiae with the Supreme Court of the United States in a case involving the characterization of income from the sale of assets as apportionable business income versus allocable nonbusiness income for state tax purposes.
41(g): In general, for individuals who are partners in a partnership, shareholders in an S corporation, or beneficiaries of a trust or estate, the allowable passedthrough RTC cannot exceed the amount of tax attributable to that portion of the individual's income that is allocable or apportionable to the individual's interest in that partnership or S corporation (Secs.