D.C. Mun. Regs. tit. 9, r. 9-169

Current through Register Vol. 71, No. 50, December 13, 2024

Rule 9-169 - COMBINED REPORTING: APPORTIONMENT

169.1

The Joyce Rule. For apportionment purposes, the principle established in Appeal of Joyce, Inc. (Cal. SBOE 11/23/66) shall apply, in which each taxpayer member of the combined group is treated as a separate taxpayer and that taxpayer's numerators will include only that taxpayer's own property, payroll, and sales factor numerators attributable to the District and will not include a share of a non-nexus member's factors. Each taxpayer member's denominator shall contain the property, payroll, and sales of the entire combined group wherever those property, payroll, and sales are attributed regardless of nexus. The following example illustrates the Joyce method:

Entity Name	District Receipts	Everywhere Receipts	District Nexus
Entity A	50	100	Yes
Entity B	100	200	Yes
Entity C	100	200	No
Factor Total	150	500

D.C. Mun. Regs. tit. 9, r. 9-169

Final Rulemaking published at 59 DCR 10875, 10894 (September 14, 2012)

Authority: The Deputy Chief Financial Officer of the District of Columbia Office of Tax and Revenue (OTR) of the Office of the Chief Financial Officer, pursuant to the authority set forth in D.C. Official Code § 47-1335 (2005 Repl.), section 201(a) of the 2005 District of Columbia Omnibus Authorization Act, approved October 16, 2006 (120 Stat. 2019; P.L. 109-356, D.C. Official Code § 1-204.24 d (2012 Supp.)) of the Home Rule Act, and the Office of the Chief Financial Officer Financial Management and Control Order No. 00-5, effective June 7, 2000.