CCH (cch.taxgroup.com) reports:
An out-of-state holding company's income from a North Carolina limited liability company (LLC) that was classified as a partnership was apportionable business income, and the holding company was required to use the LLC's payroll, sales, and property in determining its apportionment factors used to compute its North Carolina corporate income tax liability. In addition, the taxpayer's affiliated indebtedness was part of its capital includable in its corporation franchise tax base and the apportionment formula applied for apportioning its income for corporate income tax purposes was used to apportion its capital stock, surplus, and undivided profits to North Carolina for corporate franchise tax purposes.
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