C. Apportionment

C1. How is a corporation's share of the combined group's Wisconsin income computed?
C2. Is there any apportionment computation for 100% Wisconsin corporations?
C3. Are intercompany transactions eliminated when computing the apportionment factors?
C4. How does a corporation that uses a multiple-factor apportionment formula convert it to a modified
     sales factor for purposes of combined reporting?


C1. How is a corporation's share of the combined group's Wisconsin income computed?

Each corporation in the group multiplies the combined group's unitary business income by an apportionment fraction. The numerator of the fraction is the numerator of the corporation's modified sales factor. The denominator of the fraction is the sum of the denominators of all group members' modified sales factors. The "modified sales factor" is a single apportionment factor equal to a corporation's sales apportionment factor, receipts factor, or premiums factor - whichever applies to that corporation.

For companies that use multiple-factor formulas under the Department of Revenue's administrative rules, those multiple-factor formulas are converted to a modified sales factor as described in question C4.

C2. Is there any apportionment computation for 100% Wisconsin corporations?

It depends on whether there is at least one member of the combined group that is engaged in business outside Wisconsin. If there is at least one member of the combined group that is engaged in business outside Wisconsin (and at least one member that is engaged in business in Wisconsin), the entire combined group uses the apportionment computation described in question C1. However, if no corporation in the group is engaged in business in any state other than Wisconsin, the combined group does not apportion its income.

C3. Are intercompany transactions eliminated when computing the apportionment factors?

Yes, you must eliminate intercompany transactions in computing the apportionment factors of each member of the combined group.

C4. How does a corporation that uses a multiple-factor apportionment formula convert it to a modified
       sales factor for purposes of combined reporting?

The combined reporting statute (sec. 71.255(5)(a)5, Wis. Stats.) provides a formula that converts a multiple-factor apportionment formula into a modified sales factor. The steps to this formula are as follows:

FOR MORE INFORMATION PLEASE CONTACT:

WISCONSIN DEPARTMENT OF REVENUE
Phone: (608) 266-1143
Email: DORCombinedReporting@revenue.wi.gov

Page last updated January 3, 2014