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Issues Arising Under the Michigan Corporate Income Tax

Compliance Webinar Series

April 24, 2012, 10:00am EST

Sponsor: Michigan Chamber of Commerce

A Two-Part Michigan Chamber of Commerce
Compliance Webinar Series

Join us for this two-part Michigan Corporate Income Tax webinar series, which goes beyond the basics to look at the issues likely to arise when complying with the Michigan Corporate Income Tax.

Remember, multiple employees can sit around one computer screen to view the webinar for one registration (one login).

Each webinar is recorded and archived online for three (3) later viewings. If you are unavailable during the live webinar, you can still register and view the archived webinar at a later date.


Lynn A. Gandhi, Partner, Honigman Miller Schwartz and Cohn LLP

June Summers Haas, Partner, Honigman Miller Schwartz and Cohn LLP

Webinar Series

Part I - Legislative Changes & Administrative Interpretations
Tuesday, April 24, 2012
10:00 - 11:00 AM EDT

This session will update attendees on the legislative changes to the tax and administrative interpretations issued and how they impact tax return preparation, including the most troublesome calculations. The presenters will then provide an in-depth look at how the starting CIT calculation is not taken directly from the federal return, as well as commonly overlooked issues in apportionment of sales.


Recent Developments

  • Summary of CIT Legislative Changes Since Original Enactment
  • Guidance Issued by the Department of Treasury
  • Future Guidance Planned
  • Summary of CIT Proposed Legislation
  • Forms and Tax Calculation Issues

The Starting Point for the CIT Base and Differences from Federal Taxable Income Advanced Apportionment Issues

  • The Apportionable Tax Base
    • Nonbusiness or Investment Income
    • Gains from Dispositions of Capital Assets
    • Gains from Disposition of Investment Assets
    • Gains from Disposition of Flow-through Entity Interest
    • Unitary Flow-Through Entity Income
  • What is a Sale Included in the Sales Factor?
    • Gross versus Net Receipts
    • Treasury Function Transactions 
    •  Royalty Income
    • Damages, Insurance and Similar Proceeds
    • Gain from Disposition of Stock in Corporate Reorganization
  • Sourcing of Receipts from Tangibles
    • Tangible versus Intangible Income
    • Proof of Ultimate Destination
    • Consignment Sales
    • Drop Shipments
    • Client-Furnished Materials Under Cost-Plus Contract
  • Sourcing Receipts from Services
    • Sales of Tangible Personal Property versus Service Transactions
    • Standards for Where the Benefit Is Received
    • Comparison of Michigan Sourcing of Services to Other States
  • Sourcing Receipts from Intangibles
    • Patents, copyrights and similar intangibles
    • Dividends, interest and capital gains
    • Sales of investment assets and futures
    • Gross versus Net Receipts for Overnight Investments
  • Accounting for Income from Flow-Through Entities
    • Inclusion of Sales of Unitary Flow-Through Entities
    • Comparison of Other States' Treatment of Sales Factor of Flow-Through Entities
  • Consistency of Reporting to Different States

Apportionment Challenges

  • Proving distortion or misattribution of income
    • Separate Accounting
    • Processing Stage Profitability Calculations
    • Measurement of Distortion
  • Challenges to Single Sales Factor Apportionment
  • Alternative Apportionment
    • Michigan
    • Other States

Part II - The Unitary Business Group
Tuesday, May 22, 2012
10:00 - 11:00 AM EDT

This session will focus on the unitary business group and determining when a corporation enters and leaves the group, application of attribution of ownership rules and constitutional limitations on assertion of unity. The withholding rules for flow-through entities will be reviewed, along with best practices for anticipating cash withholding. This session will also discuss related issues arising from filing a combined return.


The Unitary Business Group - Beyond the Basics

  • Definition of Unitary Business
    • Comparison of Michigan to Other State Definitions
    • Most Overlooked Items
  • Control Test
    • Constitutional Requirement
    • Corporate/Shareholder Attribution
    • Related Persons Attribution
    • Examples
  • Relationship Test
    • Functional Integration
    • Flow of Value
    • Interdependence of Basic Operations
    • Separate Business
    • Examples
  • Unitary Group Structures
    • Tiered Corporate Entities
    • Brother/Sister Groups
    • Family Owned Corporations
    • Insurance, Financial and Holding Companies
    • Flow-Through Entities
  • Beginning and Ending of Unity
    • Instant Unity versus Gradual Unity
    • Filing and Reporting for Exiting Corporations
    • Transactions Straddling Unitary Groups
  • Foreign Corporations and 80/20 Companies
  • Foreign Dividends
  • Elimination of Intercompany Transactions
  • Denial of Deductions From Nonunitary Affiliates


  • Requirements for Non-Resident Individuals
  • Requirements for Corporation Members
  • Computation of Distributive Share
  • Information Requirements
  • Best Practices

Administration of the MBT

  • Return Due Dates, Estimates and Extensions
  • Penalties, Interest and Transition Rules
  • Combined Returns
    • Combined versus Consolidated Filing
    • Disclosure of Disregarded Entities
  • Accounting Issues for CIT
  • Potential Areas for Litigation


FOR ENTIRE SERIES: $110 Members / $150 Non-Members

OR PER WEBINAR: $75ea Members / $95ea Non-Members

Register Now