Skip Page Banner  
Skip Navigation

Connecticut Corporate Business Tax (Portfolio 1960)

Product Code: TPOR44
$400.00 Print
Buy Now

Connecticut Corporate Business Tax provides comprehensive discussions on a wide range of issues dealing with the taxation of corporate entities in Connecticut and considers important issues for all business enterprises doing business in the state. Written by Craig S. Wechman, Morgan Stanley LLP, and Keith H. Kruger, KPMG LLP, this Portfolio gives a detailed analysis of the federal limitations imposed on Connecticut's corporate tax scheme, including a discussion of constitutional limitations, such as the due process and commerce clauses, and federal statutory limitations, such as Pub. L. No. 86-272.  The authors also offer insight concerning the Connecticut Corporate Business Tax, specifying how the tax is computed and noting the types of activities and entities that are exempt from the tax. The discussion includes special issues affecting specific entities such as S corporations, insurance companies, and financial institutions. 

In addition, this Portfolio addresses apportionment and allocation considerations, and it describes the credits and deductions available to corporate entities.  Tax credits addressed include job creation and investment, environmental, research and development, and machinery and equipment tax credits. 

Return requirements and administrative procedures are also discussed.

Connecticut Corporate Business Tax allows you to benefit from:

  • Hundreds of hours of original research on specific tax planning topics from leading practitioners in this area.
  • Invaluable practice documents including tables, charts and lists.
  • Plain-English guidance from world-class experts.
  • Real-world and in-depth analysis that lets you explore various options.
  • Time-saving access to relevant sections of tax laws, regulations, court cases, IRS documents and more.
  • Alternative approaches to both common and unique tax scenarios.

This Portfolio is part of the Premier State Tax Library, a comprehensive series, which covers major state tax transactions and issues with expert, in-depth analysis, and offers commentary on a wide range of multi-state and state-specific taxation topics, including Sales and Use, Corporate Income, Individual Income, Property, Gross Receipts, Limitations on States' Authorities to Tax, Credits and Incentives, Electronic Commerce, Mergers and Acquisitions, Procedure and Administration, Special Industries, and more.

 

Detailed Analysis

1960.01. INTRODUCTION

1960.02. JURISDICTION TO TAX

A. Federal Limitations

B. State Overview

1960.03. EXEMPT ENTITIES

Introductory Material

A. S Corporations

B. Insurance Companies

C. Railroad Companies

D. Miscellaneous Entities

1960.04. NET INCOME TAX BASE

A. Overview

B. Additions

1. Exempt Interest Income

2. State Income Taxes

3. Related Party Transactions

4. Depreciation

C. Subtractions

1. Corporate Transactions

2. Dividend Deduction

3. Capital Loss Carryover

4. Capital Gain From Sale of Preserved Land

5. Federal Credits

6. Net Operating Losses

7. Commissioner's Discretionary Authority Regarding Related-Party Transactions

1960.05. CAPITAL STOCK TAX BASE

1960.06. APPORTIONMENT OF NET INCOME

A. Overview

B. Right to Apportion

C. Allocation

D. Single Sales Factor

E. Three Factor Formula

1. Property Factor

2. Payroll Factor

3. Sales Factor

F. General and Limited Partners Factor

G. Special Apportionment Factors

1. Motor Carriers

2. Manufacturers

3. Broadcasters

4. Financial Service Companies

a. Key Definitions

b. Determination of Apportionment Factor

c. Sourcing Specific Types of Receipts

(1) Lease or Rental Receipts

(2) Loan Receipts

(3) Receipts Related to Investment Assets

(4) Receipts From Certain Services Provided to Investment Entities

(5) Receipts From Certain Services Provided to Pension Funds or Retirement Accounts

(6) Receipts From Services Provided to Regulated Investment Companies

(7) Receipts From Credit Card Activities

(8) Receipts From Brokerage Services

(9) Receipts From Other Services

(10) Key Sourcing Definitions

1960.07. APPORTIONMENT OF CAPITAL TAX BASE

A. General Overview

B. Apportionment of Corporate Partners’ Capital Base

C. Commissioner's Authority to Change Apportionment Method

1960.08. COMBINED RETURNS

A. Overview

B. Mechanics of the Combined Return

C. Combined Net Operating Loss

D. Alternative Apportionment Method for Combined Filers

1960.09. TAX CREDITS

Introductory Material

A. Procedure for Claiming Connecticut Tax Credits

1. Ordering Rules for Credits

2. Combined Tax Credits

B. Job Creation and Investment Tax Credits

1. Enterprise Zone Tax Credit

2. Human Capital Investment Credit

3. Fixed Capital Tax Credit

4. Hiring Incentive Tax Credit

5. Apprenticeship Training Tax Credit

6. Insurance Reinvestment Fund Credit

7. Financial Institutions Credit

8. Displaced Electric Worker Credit

9. Displaced Worker Credit

10. Job Creation Credit

C. Environmental Tax Credits

1. Clean Alternative Fuel Credit

2. Urban and Industrial Site Reinvestment Credit

3. Donation of Open Space Land Credit

D. Research and Development Tax Credits

1. Non-Incremental Research and Development Credit

2. Incremental Research and Development Credit

3. Research and Development Credit for Grants to Institutions of Higher Education

4. Exchange of R& D Credits

E. Machinery and Equipment Tax Credits

1. Machinery and Equipment Expenditure Credit

2. Manufacturing Facility and Service Facility Credits

a. Manufacturing Facility Credit Percentage

b. Definition of a Manufacturing Facility

c. Service Facility Credit Percentage

d. Definition of a Service Facility

e. Determination of Tax Allocable to a Manufacturing or Service Facility

f. Occupancy and Transferability Requirements

F. Technology Tax Credits

1. Computer Donation Credit

2. Electronic Data Processing Property Tax Credit

G. Housing and Community Tax Credits

1. Historic Homes Rehabilitation Credit

2. Neighborhood Assistance Tax Credit

3. Housing Program Contribution Credit

4. Employer-Assisted Housing Tax Credit

5. Energy Conservation and Job Training

6. Child Daycare Facility Credit

7. Historic Structures Credit

H. Other Credits and Incentives

1. Small Business Guaranty Fee Tax Credit

2. Traffic Reduction Programs Credit

3. Open Space Tax Exemption

4. Movie and Digital Media Production Tax Credit

1960.10. COLLECTION AND PAYMENT OF TAX

A. Due Date of Annual Return

B. Estimated Tax Payments

C. Business Entity Tax

D. Changes by the Federal Government

E. Amended Returns

F. Protest and Appeal Process

G. Amnesty Program

Working Papers

Item Description Sheet

Worksheet 1 Conn. Dept. of Rev. Svcs., PS 2001(3) “Your Rights as a Connecticut Taxpayer”

Worksheet 2 BNA 2008 Survey of State Tax Departments: Connecticut Questionnaire

Worksheet 3 Conn. Dept. of Rev. Svcs., “Nexus Declaration”

Worksheet 4 Conn. Dept. of Rev. Svcs., SN 2002(10) “Bonus Depreciation for Connecticut Corporation Business Tax Purposes”

Worksheet 5 Conn. Dept. of Rev. Svcs., SN 93(26) “Effect of Allied-Signal, Inc. v. Director, Division of Taxation”

Worksheet 6 Millward Brown, Inc. v. Commissioner of Revenue Services

Bibliography

Bibliography

Keith Kruger
Keith H. Kruger, CPA, is a Senior Manager at KPMG LLP in Stamford, Connecticut. Mr. Kruger is also a member of the firm's state and local tax practice. A graduate of the University of Connecticut, Mr. Kruger is a member of the American Institute of Certified Public Accountants and the Connecticut Society of Certified Public Accountants. 
Craig Wechman
Craig S. Wechman, CPA, is a Senior Manager at KPMG LLP in Stamford, Connecticut. Mr. Wechman is a member of the firm's state and local tax practice, which emphasizes multistate income and franchise tax issues. A graduate of Rutgers College, Mr. Wechman received a Masters Degree in Taxation from the State University of New York at Albany. Mr. Wechman has served on the AICPA's Multistate Corporate Tax Committee.