id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-391	Weiner, Joann Martens	Practical Aspects of Implementing Formulary Apportionment in the European Union	2022	39	.pdf	application/pdf	16322	703	49	The Massachusetts Appellate Tax Board ruled that Geoffrey was liable for state income tax on an apportioned share of the more than $33 million in royalty income that it generated from its retail toy stores in Massachusetts.32 Although intangible property does not have a physical location, a non- resident company that receives substantial amounts of income from the use of that intangible property in the state does reap an economic gain from the state. Since Delaware exempts income of a Delaware holding company from state corporate income tax, Geoffrey pays no Delaware corporate income tax on the royalty income it receives from its operating companies.	cache/ftr-391.pdf	txt/ftr-391.txt