Idaho Code
Idaho Code § 63-3027 (2026)
Computing Idaho taxable income of multistate or unitary corporations.
✓ current as of May 2026
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Computing Idaho taxable income of multistate or unitary corporations.
The Idaho taxable income of any multistate or unitary corporation transacting business both within and without this state shall be computed in accordance with the provisions of this section:
Notes of Decisions
Cited in 28
cases, 1965–2020 · leading case: J.R. Simplot Co., Inc. v. Idaho State Tax Comm'n, 820 P.2d 1206 (Idaho 1991).
J.R. Simplot Co., Inc. v. Idaho State Tax Comm'n, 820 P.2d 1206 (Idaho 1991). “Idaho Code § 63-3027 , entitled "Computing taxable income of corporations," provides: "The Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the rules set forth in this section.”
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
Lockheed Martin Corp. v. Idaho State Tax Comm'n, 134 P.3d 641 (Idaho 2006). “The audit staff did not challenge that listing, but did determine that Lockheed and its subsidiaries constituted a unitary business, resulting in more of Lockheed’s income being apportioned to Idaho under Idaho Code § 63-3027 . That statute provides a formula for computing Idaho…”
ASARCO Inc. v. Idaho State Tax Comm'n, 458 U.S. 307 (1982). “[3] See Idaho Code § 63-3027 (1976 and Supp. 1981); 7A U.”
Union Pac. Corp. v. Idaho State Tax Comm'n, 83 P.3d 116 (Idaho 2004). “Union Pacific Corporation (UPC) is seeking reversal of the district court’s decision upholding the application of alternative apportionment provisions of I.C. § 63-3027 to determine that portion of UPC’s business income attributable to Idaho.”
Union Pac. Corp. v. Idaho State Tax Comm'n, 28 P.3d 375 (Idaho 2001). “The Tax Commission determined that, when apportioning income pursuant to Idaho Code § 63-3027 , Union Pacific should not have included revenues from the sale of its accounts receivable within the sales factor and it should have included as business income dividends received from…”
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
Albertson's, Inc. v. State, Dept. of Revenue, 683 P.2d 846 (Idaho 1984). “Section 63-3027(s) is an addition to the act, clarifying the application of UDITPA to unitary businesses conducted through a multicorporate structure.”
Preston v. Idaho State Tax Comm'n, 960 P.2d 185 (Idaho 1998). “Preston seeks to set off income earned by LCCA with the losses experienced by the other entities in which he held an interest, by computing his tax liability under I.”
Gee v. West, 409 P.2d 116 (Idaho 1965). “ A tax is hereby imposed for each taxable year commencing on and after January 1, 1959, * * * upon that part of the taxable income of any non-resident individual, * * * derived from sources within the state of Idaho as set forth in Section 27 (I.C. § 63-3027) hereof, * * *."…”
AIA Servs. Corp. v. Idaho State Tax Comm'n, 30 P.3d 962 (Idaho 2001). “Specifically, the Code provided: For the purpose of this section two (2) or more corporations the voting stock of which is more than fifty percent (50%) owned directly or indirectly by a common owner or owners may, when necessary to accurately reflect income, be considered a…”
Cable One, Inc. v. Idaho State Tax Comm'n, 337 P.3d 595 (Idaho 2014). “The parties stipulated to the amount of sales revenue received by Cable One in 2005 from customers in Idaho to whom it provided internet access services.”
— Idaho Code § 63-3027(a)(1) — 3 cases
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
Noell Indus. v. State Tax Comm'n (Idaho 2020).
— Idaho Code § 63-3027(a)(4) — 2 cases
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
Noell Indus. v. State Tax Comm'n (Idaho 2020).
— Idaho Code § 63-3027(a)(5) — 2 cases
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
Union Pac. Corp. v. Idaho State Tax Comm'n, 28 P.3d 375 (Idaho 2001). “The Tax Commission determined that, when apportioning income pursuant to Idaho Code § 63-3027 , Union Pacific should not have included revenues from the sale of its accounts receivable within the sales factor and it should have included as business income dividends received from…”
— Idaho Code § 63-3027(a)(l) — 2 cases
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
— Idaho Code § 63-3027(b) — 1 case
Burlington N., Inc. v. Idaho State Tax Comm'n, 828 P.2d 837 (Idaho 1992).
— Idaho Code § 63-3027(c) — 1 case
Gee v. West, 409 P.2d 116 (Idaho 1965). “ A tax is hereby imposed for each taxable year commencing on and after January 1, 1959, * * * upon that part of the taxable income of any non-resident individual, * * * derived from sources within the state of Idaho as set forth in Section 27 (I.C. § 63-3027) hereof, * * *."…”
— Idaho Code § 63-3027(d) — 4 cases
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
Albertson's, Inc. v. State, Dept. of Revenue, 683 P.2d 846 (Idaho 1984). “Section 63-3027(s) is an addition to the act, clarifying the application of UDITPA to unitary businesses conducted through a multicorporate structure.”
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
Noell Indus. v. State Tax Comm'n (Idaho 2020).
— Idaho Code § 63-3027(e) — 1 case
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
— Idaho Code § 63-3027(e)(3) — 1 case
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
— Idaho Code § 63-3027(i) — 11 cases
J.R. Simplot Co., Inc. v. Idaho State Tax Comm'n, 820 P.2d 1206 (Idaho 1991). “Idaho Code § 63-3027 , entitled "Computing taxable income of corporations," provides: "The Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the rules set forth in this section.”
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
Union Pac. Corp. v. Idaho State Tax Comm'n, 83 P.3d 116 (Idaho 2004). “Union Pacific Corporation (UPC) is seeking reversal of the district court’s decision upholding the application of alternative apportionment provisions of I.C. § 63-3027 to determine that portion of UPC’s business income attributable to Idaho.”
Union Pac. Corp. v. Idaho State Tax Comm'n, 28 P.3d 375 (Idaho 2001). “The Tax Commission determined that, when apportioning income pursuant to Idaho Code § 63-3027 , Union Pacific should not have included revenues from the sale of its accounts receivable within the sales factor and it should have included as business income dividends received from…”
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
— Idaho Code § 63-3027(i)(l) — 1 case
Health Net, Inc. v. Dept. of Rev., 22 Or. Tax 128 (Or. T.C. 2015).
— Idaho Code § 63-3027(j) — 2 cases
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
TTX Co. v. Idaho State Tax Comm'n, 915 P.2d 713 (Idaho 1996). “The portion of taxable corporate income attributable to, and properly taxable by, Idaho is defined by I.C. § 63-3027. That section provides that "[t]he Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the…”
— Idaho Code § 63-3027(k) — 1 case
Lockheed Martin Corp. v. Idaho State Tax Comm'n, 134 P.3d 641 (Idaho 2006). “The audit staff did not challenge that listing, but did determine that Lockheed and its subsidiaries constituted a unitary business, resulting in more of Lockheed’s income being apportioned to Idaho under Idaho Code § 63-3027 . That statute provides a formula for computing Idaho…”
— Idaho Code § 63-3027(m) — 2 cases
Union Pac. Corp. v. Idaho State Tax Comm'n, 28 P.3d 375 (Idaho 2001). “The Tax Commission determined that, when apportioning income pursuant to Idaho Code § 63-3027 , Union Pacific should not have included revenues from the sale of its accounts receivable within the sales factor and it should have included as business income dividends received from…”
Burlington N., Inc. v. Idaho State Tax Comm'n, 889 P.2d 79 (Idaho 1995).
— Idaho Code § 63-3027(n) — 1 case
Lockheed Martin Corp. v. Idaho State Tax Comm'n, 134 P.3d 641 (Idaho 2006). “The audit staff did not challenge that listing, but did determine that Lockheed and its subsidiaries constituted a unitary business, resulting in more of Lockheed’s income being apportioned to Idaho under Idaho Code § 63-3027 . That statute provides a formula for computing Idaho…”
— Idaho Code § 63-3027(o) — 1 case
Union Pac. Corp. v. Idaho State Tax Comm'n, 28 P.3d 375 (Idaho 2001). “The Tax Commission determined that, when apportioning income pursuant to Idaho Code § 63-3027 , Union Pacific should not have included revenues from the sale of its accounts receivable within the sales factor and it should have included as business income dividends received from…”
— Idaho Code § 63-3027(p) — 3 cases
Lockheed Martin Corp. v. Idaho State Tax Comm'n, 134 P.3d 641 (Idaho 2006). “The audit staff did not challenge that listing, but did determine that Lockheed and its subsidiaries constituted a unitary business, resulting in more of Lockheed’s income being apportioned to Idaho under Idaho Code § 63-3027 . That statute provides a formula for computing Idaho…”
Cable One, Inc. v. Idaho State Tax Comm'n, 337 P.3d 595 (Idaho 2014). “The parties stipulated to the amount of sales revenue received by Cable One in 2005 from customers in Idaho to whom it provided internet access services.”
Cable One, Inc. v. Idaho State Tax Comm'n (Idaho 2014).
— Idaho Code § 63-3027(p)(l) — 1 case
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
— Idaho Code § 63-3027(r) — 5 cases
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
Union Pac. Corp. v. Idaho State Tax Comm'n, 83 P.3d 116 (Idaho 2004). “Union Pacific Corporation (UPC) is seeking reversal of the district court’s decision upholding the application of alternative apportionment provisions of I.C. § 63-3027 to determine that portion of UPC’s business income attributable to Idaho.”
Cable One, Inc. v. Idaho State Tax Comm'n, 337 P.3d 595 (Idaho 2014). “The parties stipulated to the amount of sales revenue received by Cable One in 2005 from customers in Idaho to whom it provided internet access services.”
Cable One, Inc. v. Idaho State Tax Comm'n (Idaho 2014).
Burlington N., Inc. v. Idaho State Tax Comm'n, 889 P.2d 79 (Idaho 1995).
— Idaho Code § 63-3027(r)(2) — 2 cases
Cable One, Inc. v. Idaho State Tax Comm'n, 337 P.3d 595 (Idaho 2014). “The parties stipulated to the amount of sales revenue received by Cable One in 2005 from customers in Idaho to whom it provided internet access services.”
Cable One, Inc. v. Idaho State Tax Comm'n (Idaho 2014).
— Idaho Code § 63-3027(s) — 6 cases
J.R. Simplot Co., Inc. v. Idaho State Tax Comm'n, 820 P.2d 1206 (Idaho 1991). “Idaho Code § 63-3027 , entitled "Computing taxable income of corporations," provides: "The Idaho taxable income of any corporation with a business situs in this state shall be computed and taxed in accordance with the rules set forth in this section.”
Am. Smelting & Refining Co. v. Idaho State Tax Comm'n, 592 P.2d 39 (Idaho 1979). “I.C. § 63-3027. The Act contains rules for determining the portion of a corporation’s total income from a multistate business which is attributable to this state and therefore subject to Idaho’s income tax.”
AIA Servs. Corp. v. Idaho State Tax Comm'n, 30 P.3d 962 (Idaho 2001). “Specifically, the Code provided: For the purpose of this section two (2) or more corporations the voting stock of which is more than fifty percent (50%) owned directly or indirectly by a common owner or owners may, when necessary to accurately reflect income, be considered a…”
Union Pac. Corp. v. Idaho State Tax Comm'n, 83 P.3d 116 (Idaho 2004). “Union Pacific Corporation (UPC) is seeking reversal of the district court’s decision upholding the application of alternative apportionment provisions of I.C. § 63-3027 to determine that portion of UPC’s business income attributable to Idaho.”
Albertson's, Inc. v. State, Dept. of Revenue, 683 P.2d 846 (Idaho 1984). “Section 63-3027(s) is an addition to the act, clarifying the application of UDITPA to unitary businesses conducted through a multicorporate structure.”
— Idaho Code § 63-3027(t) — 1 case
Lockheed Martin Corp. v. Idaho State Tax Comm'n, 134 P.3d 641 (Idaho 2006). “The audit staff did not challenge that listing, but did determine that Lockheed and its subsidiaries constituted a unitary business, resulting in more of Lockheed’s income being apportioned to Idaho under Idaho Code § 63-3027 . That statute provides a formula for computing Idaho…”
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