Rhode Island Code of Regulations
Title 280 - Department of Revenue
Chapter 20 - Division of Taxation
Subchapter 25 - Business Corporation Tax
Part 10 - Combined Reporting (280-RICR-20-25-10)
Section 280-RICR-20-25-10.6 - Combined Reporting - Overview
Current through September 18, 2024
A. For tax years beginning on or after January 1, 2015, each entity treated as a C corporation for federal income tax purposes which is part of a combined group, under common ownership, and engaged in a unitary business with one or more other corporations must file a return, in a manner prescribed by the Tax Administrator, for the combined group containing the combined income of the combined group. (See, also, § 10.17 of this Part, "Filing of Return," and § 10.19 of this Part, "Designated Agent.")
B. Where an entity treated as a C corporation for federal income tax purposes is taxed or will be taxed under R.I. Gen. Laws Chapter 44-11, the entity must determine its Rhode Island tax liability based upon the income and apportionment information of all corporations included in the combined group using a combined return, unless it is an excluded entity as further described in § 10.7 of this Part. The use of a combined return does not disregard the separate identities of the members of the combined group; each taxpayer member is responsible for tax based on its taxable income or loss apportioned to Rhode Island. (See also "Designated Agent" in § 10.19 of this Part.)
C. "Combined return" is not, in and of itself, a tax return; it is, in fact, a computational schedule or schedules - as required by Rhode Island General Laws and regulations - which are to be attached to a taxpayer member's tax return and which report the income and apportionment information of all entities of the taxpayer member's combined group, as well as any supporting information required by the Tax Administrator. The combined return shall include, for each taxable year, the following:
D. The following example shows how related entities might be affected by combined reporting. For purposes of apportionment calculations in this example, the denominators reflect worldwide sales for corporations that are included in the combined group.
Apportionment: |
Echo Corp (Separate) |
Foxtrot Corp (Separate) |
Golf Corp (Separate) |
Combined Return |
Sales Factor In-State Sales Everywhere Sales Sales Percentage |
$400 $600 64.0000% |
$7,700 $15,000 51.3333% |
$0 $50,000 0.0000% |
$8,100 $65,625 12.3429% |
Taxable Income Total |
$75 |
$900 |
$7,500 |
$8,475 |
In-State Taxable Income |
$48 |
$462 |
$0 |
$1046 |
Total Taxable Income to Rhode Island |
$510 |
$1046 |