Me. Rev. Stat. » Title 36
Maine Revised Statutes

Me. Rev. Stat. tit. 36, § 5211 (2026)

General

✓ current as of May 2026
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1.  Apportionment.  A taxpayer, other than a resident individual, estate or trust, having income from business activity that is taxable both within and without this State, other than the rendering of purely personal services by an individual, shall apportion that taxpayer's net income as provided in this section. A taxpayer having income solely from business activity taxable within this State shall apportion that taxpayer's entire net income to this State.  
[RR 2025, c. 1, Pt. F, §24 (COR).]
2.  Taxpayer taxable in another state.  For purposes of apportionment of income under this section, a taxpayer is taxable in another state if in that state that taxpayer is subject to a net income tax, a franchise tax measured by net income, a franchise tax for the privilege of doing business or a corporate stock tax or that state has jurisdiction to subject the taxpayer to a net income tax regardless of whether in fact the state does or does not.  
[RR 2025, c. 1, Pt. F, §25 (COR).]
3.  Allocation of certain nonbusiness income. 
[PL 1987, c. 841, §11 (RP).]
4.  Rents and royalties: 
[PL 1987, c. 841, §11 (RP).]
5.  Capital gains and losses: 
[PL 1987, c. 841, §11 (RP).]
6.  Commercial domicile in this State. 
[PL 1987, c. 841, §11 (RP).]
7.  Patent and copyright royalties: 
[PL 1987, c. 841, §11 (RP).]
8.  Formula for apportionment of income to State.  All income shall be apportioned to this State by multiplying the income by the sales factor.  
[PL 2007, c. 240, Pt. V, §2 (AMD); PL 2007, c. 240, Pt. V, §15 (AFF).]
9.  Property factor.  The property factor is a fraction, the numerator of which is the average value of the taxpayer's real and tangible personal property owned or rented and used in this State during the tax period and the denominator of which is the average value of all the taxpayer's real and tangible personal property owned or rented and used during the tax period.  
[PL 2007, c. 627, §84 (REEN); PL 2007, c. 627, §96 (AFF).]
10.  Property valuation at original cost.  Property owned by the taxpayer is valued at its original cost. Property rented by the taxpayer is valued at 8 times the net annual rental rate. Net annual rental rate is the annual rental rate paid by the taxpayer.  
[PL 2007, c. 627, §85 (REEN); PL 2007, c. 627, §96 (AFF).]
11.  Determination of average value of property.  The average value of property shall be determined by averaging the values at the beginning and ending of the tax period but the Tax Assessor may require the averaging of monthly values during the tax period if reasonably required to reflect properly the average value of the taxpayer's property.  
[PL 2007, c. 627, §86 (REEN); PL 2007, c. 627, §96 (AFF).]
12.  Payroll factor.  The payroll factor is a fraction, the numerator of which is the total amount paid in this State during the tax period by the taxpayer for compensation, and the denominator of which is the total compensation paid everywhere during the tax period. Eighty-five percent of any amounts paid pursuant to a contract by the taxpayer to an employee-leasing company for leased employees, and 100% of the amount paid pursuant to a contract to a temporary services company for temporary employees, must be included in the taxpayer's payroll factor. The payroll factor of an employee-leasing company or a temporary services company must exclude compensation paid to leased or temporary employees who are providing personal services to client companies.  
[PL 2007, c. 627, §87 (REEN); PL 2007, c. 627, §96 (AFF).]
13.  When compensation paid in this State.  Compensation is paid in this State, if:  
A. The individual's service is performed entirely within the State; or   [PL 2007, c. 627, §88 (REEN); PL 2007, c. 627, §96 (AFF).]
B. The individual's service is performed both within and without the State, but the service performed without the state is incidental to the individual's service within the State; or   [PL 2007, c. 627, §88 (REEN); PL 2007, c. 627, §96 (AFF).]
C. Some of the service is performed in the State and the base of operations or, if there is no base of operations, the place from which the service is directed or controlled is in the State, or the base of operations or the place from which the service is directed or controlled is not in any state in which some part of the service is performed, but the individual's residence is in this State.   [PL 2007, c. 627, §88 (REEN); PL 2007, c. 627, §96 (AFF).]
[PL 2007, c. 627, §88 (REEN); PL 2007, c. 627, §96 (AFF).]
14.  Sales factor formula.  The sales factor is a fraction, the numerator of which is the total sales of the taxpayer in this State during the tax period, and the denominator of which is the total sales of the taxpayer everywhere during the tax period.  
A. For purposes of calculating the sales factor, "total sales of the taxpayer" includes sales of the taxpayer and of any member of an affiliated group with which the taxpayer conducts a unitary business.   [PL 2021, c. 181, Pt. E, §3 (NEW); PL 2021, c. 181, Pt. E, §4 (AFF).]
B. The sales factor formula must exclude from both the numerator and the denominator sales of tangible personal property delivered or shipped by the taxpayer, regardless of F.O.B. point or other conditions of the sale, to a purchaser within a state in which the taxpayer is not taxable within the meaning of subsection 2, unless any member of an affiliated group with which the taxpayer conducts a unitary business is taxable in that state in the same manner as a taxpayer is taxable under subsection 2.   [PL 2021, c. 181, Pt. E, §3 (NEW); PL 2021, c. 181, Pt. E, §4 (AFF).]
[PL 2021, c. 181, Pt. E, §3 (AMD); PL 2021, c. 181, Pt. E, §4 (AFF).]
15.  When sales of tangible personal property are in this State.  Sales of tangible personal property are in this State if:  
A. The property is delivered or shipped to a purchaser, other than the United States Government, within this State regardless of the F.O.B. point or other conditions of the sale; or   [P&SL 1969, c. 154, §F/§1 (NEW).]
B. The property is shipped from an office, store, warehouse, factory or other place of storage in this State and the purchaser is the United States Government.   [PL 2009, c. 213, Pt. NN, §2 (AMD); PL 2009, c. 213, Pt. NN, §5 (AFF).]
[PL 2009, c. 213, Pt. NN, §2 (AMD); PL 2009, c. 213, Pt. NN, §5 (AFF).]
16.  When sales other than tangible personal property are in State. 
[PL 2007, c. 240, Pt. V, §8 (RP); PL 2007, c. 240, Pt. V, §15 (AFF).]
16-A.  Other sales.  Sales other than sales of tangible personal property are sourced as follows.  
A. Except as otherwise provided by this subsection, receipts from the performance of services must be attributed to the state where the services are received. If the state where the services are received is not readily determinable, the services are deemed to be received at the home of the customer or, in the case of a business, the office of the customer from which the services were ordered in the regular course of the customer's trade or business. If the ordering location cannot be determined, the services are deemed to be received at the home or office of the customer to which the services are billed. In instances in which the purchaser of the service is the Federal Government, the receipts are attributable to this State if a greater proportion of the income-producing activity is performed in this State than in any other state based on costs of performance.   [PL 2009, c. 213, Pt. NN, §3 (AMD); PL 2009, c. 213, Pt. NN, §5 (AFF).]
B. Gross receipts from the license, sale or other disposition of patents, copyrights, trademarks or similar items of intangible personal property must be attributed to this State if the intangible property is used in this State by the licensee. If the intangible personal property is used by the licensee in more than one state, the income must be apportioned to this State according to the portion of use in this State. In instances in which the purchaser or licensee of the intangible personal property is the Federal Government, the receipts are attributable to this State if a greater proportion of the income-producing activity is performed in this State than in any other state based on costs of performance.   [PL 2009, c. 213, Pt. NN, §4 (AMD); PL 2009, c. 213, Pt. NN, §5 (AFF).]
C. Receipts from the sale, lease, rental or other use of real property is sourced to this State if the real property is located in this State.   [PL 2007, c. 240, Pt. V, §9 (NEW); PL 2007, c. 240, Pt. V, §15 (AFF).]
D. Receipts from the lease or rental of tangible personal property must be attributed to this State if the property is located in this State.   [PL 2007, c. 240, Pt. V, §9 (NEW); PL 2007, c. 240, Pt. V, §15 (AFF).]
E. Receipts from items of income described in section 5206‑E, subsection 2, paragraphs C to I must be sourced to this State as provided in those paragraphs. For purposes of this paragraph, section 5206‑E, subsection 2, paragraphs G and H must include the related payment processing fees.   [PL 2007, c. 240, Pt. V, §9 (NEW); PL 2007, c. 240, Pt. V, §15 (AFF).]
F. Gross receipts on the sale of a partnership interest must be sourced to this State in an amount equal to the gross receipts multiplied by the ratio obtained by dividing the original cost of partnership tangible property located in Maine by the original cost of partnership tangible property everywhere, determined at the time of the sale. Tangible property includes property owned or rented and is valued in accordance with subsection 10. If more than 50% of the value of the partnership's assets consists of intangible property, gross receipts from the sale of the partnership interest must be sourced to this State in accordance with the sales factor of the partnership for its first full tax period immediately preceding the tax period of the partnership during which the partnership interest was sold. For purposes of this paragraph, the sales factor of a partnership is determined in accordance with subsection 14, subsection 15 and subsection 16‑A, paragraphs A to E. This paragraph does not apply to the sale of a limited partner's interest in an investment partnership when more than 80% of the value of the partnership's total assets consists of intangible personal property held for investment, except that such property cannot include an interest in a partnership unless that partnership is itself an investment partnership.   [PL 2019, c. 401, Pt. C, §9 (RPR); PL 2019, c. 401, Pt. C, §16 (AFF).]
[PL 2019, c. 401, Pt. C, §9 (AMD); PL 2019, c. 401, Pt. C, §16 (AFF).]
16-B.  Sales factor formula for certain disaster period receipts.  The sales factor must exclude from the numerator sales receipts of a person whose only business activity in the State during the taxable year is the performance of services during a disaster period that are solely and directly related to a declared state disaster or emergency that were requested by the State, a county, city, town or political subdivision of the State or a registered business.  
[RR 2011, c. 2, §42 (COR).]
17.  Variations.  If the apportionment provisions of this section do not fairly represent the extent of the taxpayer's business activity in this State, the taxpayer may petition for, or the tax assessor may require, in respect to all or any part of the taxpayer's business activity, if reasonable:  
A. Separate accounting; or   [PL 2007, c. 240, Pt. V, §10 (AMD); PL 2007, c. 240, Pt. V, §15 (AFF).]
B. [PL 2007, c. 240, Pt. V, §11 (RP); PL 2007, c. 240, Pt. V, §15 (AFF).]
C. [PL 2007, c. 240, Pt. V, §12 (RP); PL 2007, c. 240, Pt. V, §15 (AFF).]
D. The employment of any other method to effectuate an equitable apportionment of the taxpayer's income.   [PL 1987, c. 841, §13 (AMD).]
[PL 2007, c. 240, Pt. V, §§10-12 (AMD); PL 2007, c. 240, Pt. V, §15 (AFF).]
SECTION HISTORY
P&SL 1969, c. 154, §F/§1 (NEW). PL 1987, c. 841, §§10-13 (AMD). PL 1991, c. 502, §1 (AMD). PL 1991, c. 502, §2 (AFF). PL 1999, c. 708, §43 (AMD). PL 2001, c. 439, §D8 (AMD). PL 2001, c. 439, §D9 (AFF). PL 2005, c. 12, §MMMM2 (AMD). PL 2005, c. 12, §MMMM3 (AFF). PL 2007, c. 240, Pt. V, §§2-12 (AMD). PL 2007, c. 240, Pt. V, §15 (AFF). PL 2007, c. 627, §§84-88 (AMD). PL 2007, c. 627, §96 (AFF). PL 2009, c. 213, Pt. NN, §§1-4 (AMD). PL 2009, c. 213, Pt. NN, §5 (AFF). PL 2009, c. 571, Pt. GG, §1 (AMD). PL 2009, c. 571, Pt. GG, §2 (AFF). RR 2011, c. 2, §42 (COR). PL 2011, c. 622, §6 (AMD). PL 2011, c. 622, §7 (AFF). PL 2019, c. 401, Pt. C, §9 (AMD). PL 2019, c. 401, Pt. C, §16 (AFF). PL 2021, c. 181, Pt. E, §3 (AMD). PL 2021, c. 181, Pt. E, §4 (AFF). RR 2025, c. 1, Pt. F, §§24, 25 (COR).
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Notes of Decisions
Cited in 18 cases (2 in the last 5 years), 1978–2023 · leading case: State Tax Assessor v. Kraft Foods Grp., Inc., 2020 ME 81 (Me. 2020).
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State Tax Assessor v. Kraft Foods Grp., Inc., 2020 ME 81 (Me. 2020). · cites it 16× “4, 1988) (repealing subsection 3 of 36 M.R.S. § 5211, which provided for allocation of certain nonbusiness income).”
Great N. Nekoosa Corp. v. State Tax Assessor, 675 A.2d 963 (Me. 1996). · cites it 19× “36 M.R.S.A. § 5211(14) The property and payroll factors in section 5211(8) are similarly defined.”
E.I. Du Pont De Nemours & Co. v. State Tax Assessor, 675 A.2d 82 (Me. 1996). · cites it 10× “There is no indication in the legislative record that any of these provisions, including the amendment relied on by Du Pont, [7] precluded the Assessor from resorting *86 to the worldwide combined reporting method pursuant to the equitable apportionment provision of 36 M.R.S.A.…”
Gannett Co., Inc. v. State Tax Assessor, 2008 ME 171 (Me. 2008). · cites it 5× “In addition, we review de novo the constitutionality of Maine’s tax apportionment formula, 36 M.R.S.A. § 5211 (1990 & Supp.2000), 1 as it applies to Gannett.”
Irving Pulp & Paper, Ltd. v. State Tax Assessor, 2005 ME 96 (Me. 2005). · cites it 5× “The sales factor is a fraction, the numerator of which is the total sales of the taxpayer in this State during the tax period, and the denominator of which is the total sales of the taxpayer everywhere during the tax period.”
Albany Int'l Corp. v. Halperin, 388 A.2d 902 (Me. 1978). · cites it 6× “On the basis of those facts, the State Tax Assessor determined that in view of the degree of control over the various divisions that is vested in appellant and the relationship of the various divisions within the corporate structure, separate accounting by the Globe Albany…”
Tambrands, Inc. v. State Tax Assessor, 595 A.2d 1039 (Me. 1991). · cites it 4× “Apportioning the income of a multi-national multi-state unitary business between different tax jurisdictions is a task that has been aptly described as attempting to slice a shadow.”
Express Scripts Inc. et al., 2023 ME 68 (Me. 2023). · cites it 9× “• In Count 2, Express Scripts argued in the alternative that pursuant to 36 M.R.S. § 5211(16-A)(A), if the location where its services were received is not readily determinable, those receipts should be attributed to its clients’ commercial and administrative headquarters…”
Somerset Tel. Co. v. State Tax Assessor, 2021 ME 26 (Me. 2021). · cites it 2× “36 M.R.S. § 5211(1) (2011); 36 M.R.S. § 5211(1) (2021).”
Preti Flaherty Beliveau & Pachios LLP v. State Tax Assessor, 2014 ME 6 (Me. 2014). “Title 36 M.R.S. § 5211(17) (2013) provides: Variations.”
State Tax Assessor v. Kraft Groods Grp., Inc. (Me. Super. Ct 2017). · cites it 11× “Sections 5211 through 5212 of Title 36 of the Maine Revised Statutes, titled "Apportionment of Income," describe the process by which taxable corporations and affiliated groups of corporations that "hav[e] income from business activity which is taxable both within and without…”
Nelnet, Inc. v. State Tax Assessor (Me. Super. Ct 2008). · cites it 8× “The applicable statute is 36 M.R.S. § 5211. Corporate taxpayers that have income from business that is taxable both within and outside of Maine are required to apportion their net income on the basis of a statutory formula.”
Show all 18 citing cases →
— Me. Rev. Stat. tit. 36, § 5211(1) — 7 cases
State Tax Assessor v. Kraft Foods Grp., Inc., 2020 ME 81 (Me. 2020). “4, 1988) (repealing subsection 3 of 36 M.R.S. § 5211, which provided for allocation of certain nonbusiness income).”
Somerset Tel. Co. v. State Tax Assessor, 2021 ME 26 (Me. 2021). “36 M.R.S. § 5211(1) (2011); 36 M.R.S. § 5211(1) (2021).”
Gannett Co., Inc. v. State Tax Assessor, 2008 ME 171 (Me. 2008). “In addition, we review de novo the constitutionality of Maine’s tax apportionment formula, 36 M.R.S.A. § 5211 (1990 & Supp.2000), 1 as it applies to Gannett.”
State Tax Assessor v. Kraft Groods Grp., Inc. (Me. Super. Ct 2017). “Sections 5211 through 5212 of Title 36 of the Maine Revised Statutes, titled "Apportionment of Income," describe the process by which taxable corporations and affiliated groups of corporations that "hav[e] income from business activity which is taxable both within and without…”
Nelnet, Inc. v. State Tax Assessor (Me. Super. Ct 2008). “The applicable statute is 36 M.R.S. § 5211. Corporate taxpayers that have income from business that is taxable both within and outside of Maine are required to apportion their net income on the basis of a statutory formula.”
— Me. Rev. Stat. tit. 36, § 5211(12) — 1 case
Irving Pulp & Paper, Ltd. v. State Tax Assessor, 2005 ME 96 (Me. 2005). “The sales factor is a fraction, the numerator of which is the total sales of the taxpayer in this State during the tax period, and the denominator of which is the total sales of the taxpayer everywhere during the tax period.”
— Me. Rev. Stat. tit. 36, § 5211(14) — 5 cases
Great N. Nekoosa Corp. v. State Tax Assessor, 675 A.2d 963 (Me. 1996). “36 M.R.S.A. § 5211(14) The property and payroll factors in section 5211(8) are similarly defined.”
State Tax Assessor v. Kraft Foods Grp., Inc., 2020 ME 81 (Me. 2020). “4, 1988) (repealing subsection 3 of 36 M.R.S. § 5211, which provided for allocation of certain nonbusiness income).”
Express Scripts Inc. et al., 2023 ME 68 (Me. 2023). “• In Count 2, Express Scripts argued in the alternative that pursuant to 36 M.R.S. § 5211(16-A)(A), if the location where its services were received is not readily determinable, those receipts should be attributed to its clients’ commercial and administrative headquarters…”
State Tax Assessor v. Kraft Groods Grp., Inc. (Me. Super. Ct 2017). “Sections 5211 through 5212 of Title 36 of the Maine Revised Statutes, titled "Apportionment of Income," describe the process by which taxable corporations and affiliated groups of corporations that "hav[e] income from business activity which is taxable both within and without…”
Nelnet, Inc. v. State Tax Assessor (Me. Super. Ct 2008). “The applicable statute is 36 M.R.S. § 5211. Corporate taxpayers that have income from business that is taxable both within and outside of Maine are required to apportion their net income on the basis of a statutory formula.”
— Me. Rev. Stat. tit. 36, § 5211(15) — 1 case
Nelnet, Inc. v. State Tax Assessor (Me. Super. Ct 2008). “The applicable statute is 36 M.R.S. § 5211. Corporate taxpayers that have income from business that is taxable both within and outside of Maine are required to apportion their net income on the basis of a statutory formula.”
— Me. Rev. Stat. tit. 36, § 5211(15)(B) — 1 case
Great N. Nekoosa Corp. v. State Tax Assessor, 675 A.2d 963 (Me. 1996). “36 M.R.S.A. § 5211(14) The property and payroll factors in section 5211(8) are similarly defined.”
— Me. Rev. Stat. tit. 36, § 5211(16) — 1 case
Nelnet, Inc. v. State Tax Assessor (Me. Super. Ct 2008). “The applicable statute is 36 M.R.S. § 5211. Corporate taxpayers that have income from business that is taxable both within and outside of Maine are required to apportion their net income on the basis of a statutory formula.”
— Me. Rev. Stat. tit. 36, § 5211(16)(B) — 1 case
Nelnet, Inc. v. State Tax Assessor (Me. Super. Ct 2008). “The applicable statute is 36 M.R.S. § 5211. Corporate taxpayers that have income from business that is taxable both within and outside of Maine are required to apportion their net income on the basis of a statutory formula.”
— Me. Rev. Stat. tit. 36, § 5211(17) — 11 cases
E.I. Du Pont De Nemours & Co. v. State Tax Assessor, 675 A.2d 82 (Me. 1996). “There is no indication in the legislative record that any of these provisions, including the amendment relied on by Du Pont, [7] precluded the Assessor from resorting *86 to the worldwide combined reporting method pursuant to the equitable apportionment provision of 36 M.R.S.A.…”
State Tax Assessor v. Kraft Foods Grp., Inc., 2020 ME 81 (Me. 2020). “4, 1988) (repealing subsection 3 of 36 M.R.S. § 5211, which provided for allocation of certain nonbusiness income).”
Tambrands, Inc. v. State Tax Assessor, 595 A.2d 1039 (Me. 1991). “Apportioning the income of a multi-national multi-state unitary business between different tax jurisdictions is a task that has been aptly described as attempting to slice a shadow.”
Preti Flaherty Beliveau & Pachios LLP v. State Tax Assessor, 2014 ME 6 (Me. 2014). “Title 36 M.R.S. § 5211(17) (2013) provides: Variations.”
Great N. Nekoosa Corp. v. State Tax Assessor, 675 A.2d 963 (Me. 1996). “36 M.R.S.A. § 5211(14) The property and payroll factors in section 5211(8) are similarly defined.”
— Me. Rev. Stat. tit. 36, § 5211(17)(D) — 4 cases
Express Scripts Inc. et al., 2023 ME 68 (Me. 2023). “• In Count 2, Express Scripts argued in the alternative that pursuant to 36 M.R.S. § 5211(16-A)(A), if the location where its services were received is not readily determinable, those receipts should be attributed to its clients’ commercial and administrative headquarters…”
State Tax Assessor v. Kraft Groods Grp., Inc. (Me. Super. Ct 2017). “Sections 5211 through 5212 of Title 36 of the Maine Revised Statutes, titled "Apportionment of Income," describe the process by which taxable corporations and affiliated groups of corporations that "hav[e] income from business activity which is taxable both within and without…”
Irving Pulp & Paper Ltd. v. Maine Revenue Servs. (Me. Super. Ct 2004).
Preti Flaherty Beliveau & Pacios v. State Tax Assessor (Me. Super. Ct 2013).
— Me. Rev. Stat. tit. 36, § 5211(2) — 1 case
Great N. Nekoosa Corp. v. State Tax Assessor, 675 A.2d 963 (Me. 1996). “36 M.R.S.A. § 5211(14) The property and payroll factors in section 5211(8) are similarly defined.”
— Me. Rev. Stat. tit. 36, § 5211(8) — 7 cases
State Tax Assessor v. Kraft Foods Grp., Inc., 2020 ME 81 (Me. 2020). “4, 1988) (repealing subsection 3 of 36 M.R.S. § 5211, which provided for allocation of certain nonbusiness income).”
E.I. Du Pont De Nemours & Co. v. State Tax Assessor, 675 A.2d 82 (Me. 1996). “There is no indication in the legislative record that any of these provisions, including the amendment relied on by Du Pont, [7] precluded the Assessor from resorting *86 to the worldwide combined reporting method pursuant to the equitable apportionment provision of 36 M.R.S.A.…”
Irving Pulp & Paper, Ltd. v. State Tax Assessor, 2005 ME 96 (Me. 2005). “The sales factor is a fraction, the numerator of which is the total sales of the taxpayer in this State during the tax period, and the denominator of which is the total sales of the taxpayer everywhere during the tax period.”
Albany Int'l Corp. v. Halperin, 388 A.2d 902 (Me. 1978). “On the basis of those facts, the State Tax Assessor determined that in view of the degree of control over the various divisions that is vested in appellant and the relationship of the various divisions within the corporate structure, separate accounting by the Globe Albany…”
Great N. Nekoosa Corp. v. State Tax Assessor, 675 A.2d 963 (Me. 1996). “36 M.R.S.A. § 5211(14) The property and payroll factors in section 5211(8) are similarly defined.”
— Me. Rev. Stat. tit. 36, § 5211(9) — 2 cases
Irving Pulp & Paper, Ltd. v. State Tax Assessor, 2005 ME 96 (Me. 2005). “The sales factor is a fraction, the numerator of which is the total sales of the taxpayer in this State during the tax period, and the denominator of which is the total sales of the taxpayer everywhere during the tax period.”
State Tax Assessor v. Kraft Groods Grp., Inc. (Me. Super. Ct 2017). “Sections 5211 through 5212 of Title 36 of the Maine Revised Statutes, titled "Apportionment of Income," describe the process by which taxable corporations and affiliated groups of corporations that "hav[e] income from business activity which is taxable both within and without…”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.