R.C.S.A. § 12-218-1
Definitions
Cite as Conn. Agencies Regs. § 12-218-1
(a) "Entire net income" means net income apportioned to this state under section 12-218.
Only a company which is taxable both within and without this state shall be entitled
to apportion its net income to this state. In the case of a company which is not taxable
both within and without this state, any reference to its entire net income means its
net income.
(b) "Entire net loss" means the excess (of allowable deductions over gross income) apportioned
to this state under section 12-218. Only a company which is taxable both within and
without this state shall be entitled to apportion its excess (of allowable deductions
over gross income) to this state. In the case of a company which is not taxable both
within and without this state, any reference to its entire net loss means its excess
of allowable deductions over gross income.
(c) The commissioner, in his discretion, may require a company which files its annual
return as if it were "taxable both within and without this state" to submit an official
ruling from a state (which purportedly has taxing jurisdiction over such company)
concerning its jurisdiction to impose a net income tax, a franchise tax for the privilege
of doing business or a corporate stock tax on such company. Such an official ruling
shall in no event bind the commissioner or be deemed conclusive.
(d) The "principal place of business" of a company is deemed to be within this state if
the nerve center from which its officers control and coordinate corporate activities
in furtherance of corporate objectives is within this state, or if the location of
its overall, active management is within this state.
(e) Interest income and intangible assets are "managed or controlled" by a company within
this state if—
(1) an office separate and distinct (if applicable) from the principal place of business
of such company and officers of such company, charged with or responsible for the
administration of, and the routine corporate activities involving, this particular
aspect (interest income and intangible assets) of business operations are within this
state; or
((2))