Examples of California Partnerships in a sentence
There was no other flow of value between the New York and California Partnerships or between Petitioner and those Partnerships.
Petitioner and the New York and California Partnerships did not engage in a unitary business as there was no functional integration, centralization of management or economies of scale between them.
The fact that Mr. Otto, intending to benefit his children, chose to make investments through a series of percentage interests in limited partnerships which separately and together held various parcels of real property in the United States, does not establish that Petitioner and the New York and California Partnerships were engaged in a unitary business.
See, e.g., Container Corp., supra.Although the New York and California Partnerships are engaged in the same line of business (ownership of commercial real property), they are not engaged in a unitary business.
Even if Petitioner and the New York and California Partnerships had been engaged in a unitary business, as the Court found with respect to British Land (Maryland), as in that case, the gain from the Sale is not constitutionally taxable as it is primarily attributed to California factors.
Thus, the Commissioner can only require Petitioner to include income from non- City sources in ENI if the New York and California Partnerships, among themselves and with Petitioner, are involved in a unitary business.
It is responsive to the California Oral Health Plan 2018-2028 and Healthy People 2030 Oral Health objective, which is to Increase the number of states and DC that have an oral and craniofacial health surveillance system — OH-D01.The OOH also successfully developed the California Partnerships for Oral Health Plan (2021) and established the California Partnership for Oral Health (Partnership).
On its 2001 California Return, Petitioner apportioned 48.7744% of the combined business income of the New York and California Partnerships to California.5 Petitioner filed its 2002 GCT Return calculating its tax liability by using a separate accounting method that excluded the gain from the sale of the California Property from ENI, and those factors that were attributable to the California Partnership from the BAP.
Moreover, even if the New York and California Partnerships were engaged in a unitary business, non-City income may be excluded from the ENI base where the apportionment to the City “attributes income to petitioner ‘out of all appropriate proportion to the business transacted by [it]’” in the City.
The New York and California Partnerships were established to own and manage one property each.