Payroll Factor: Denominator (Rule 505)

Section 63-3027(16)(d), Idaho Code 01. In General. The denominator of the payroll factor is the total compensation paid everywhere during the taxable year. Accordingly, compensation paid to employees whose services are performed entirely in a state where the taxpayer is immune from taxation, for example, by Public Law 86-272, is included in the denominator of the payroll factor. The denominator may not exceed the sum of all numerators. (4-6-23) 02. Example. A taxpayer has employees in States A, B, and C. However, in State C the taxpayer is immune from taxation by Public Law 86-272. The compensation paid to employees for services performed in State C IDAHO ADMINISTRATIVE CODE IDAPA 35.01.01 Idaho State Tax Commission Income Tax Administrative Rules Section 510 Page 69 is assigned to that state. This compensation is included in the denominator even though the taxpayer is not taxable in State C. (4-6-23) 506. -- 509. (RESERVED)