169. COMBINED REPORTING: APPORTIONMENT

169 COMBINED REPORTING: APPORTIONMENT 169.1 The Joyce Rule. For apportionment purposes, the principle established in Appeal of Joyce, Inc. (Cal. SBOE 11/23/66) shall apply, in which each taxpayer member of the combined group is treated as a separate taxpayer and that taxpayer’s numerators will include only that taxpayer’s own property, payroll, and sales factor numerators attributable to the District and will not include a share of a non-nexus member’s factors. Each taxpayer member’s denominator shall contain the property, payroll, and sales of the entire combined group wherever those property, payroll, and sales are attributed regardless of nexus. The following example illustrates the Joyce method: Entity Name District Receipts Everywhere Receipts District Nexus Entity A 50 100 Yes Entity B 100 200 Yes Entity C 100 200 No Factor Total 150 500 SOURCE: Final Rulemaking published at 59 DCR 10875, 10894 (September 14, 2012).