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Oregon Revised Statutes

Or. Rev. Stat. § 314.615 (2026)

When allocation and apportionment of net income from business activity required

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      314.615 When allocation and apportionment of net income from business activity required. Any taxpayer having income from business activity which is taxable both within and without this state, other than activity as a financial institution or public utility or the rendering of purely personal services by an individual, shall allocate and apportion the net income of the taxpayer as provided in ORS 314.605 to 314.675. Taxpayers engaged in activities as a financial institution or public utility shall report their income as provided in ORS 314.280 and 314.675. [1965 c.152 §3; 2001 c.793 §6; 2001 c.933 §5; 2009 c.403 §6]

Notes of Decisions
Cited in 49 cases (7 in the last 5 years), 1969–2025 · leading case: Oracle Corp. v. Dept. of Rev., 24 Or. Tax 359 (Or. T.C. 2021).
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Oracle Corp. v. Dept. of Rev., 24 Or. Tax 359 (Or. T.C. 2021). · cites it 5× “Therefore, if the income was business income, it also fit within the definition of “sales.” As to the “sourcing” methods, UDITPA contained one method for sales of tangible personal property, and another method for all other kinds of sales, reflecting UDITPA’s ori- gins at a time…”
Caterpillar Tractor Co. v. Dept. of Revenue, 618 P.2d 1261 (Or. 1980). · cites it 7× “The practice of combined reporting and the factors that trigger its applicability are described in the administrative rules implementing ORS 314.615. Basically, ORS 314.615 requires a taxpayer with income from interrelated business activity within and outside of the State of…”
Tektronix, Inc. v. Dep't of Revenue, 316 P.3d 276 (Or. 2013). ““Sales” is statutorily defined as follows: “‘Sales’ means all gross receipts of the taxpayer not allocated under ORS 314.615 to 314.645.” ORS 314.610(7). 7 The statute that sets out the method for calculating the sales factor, ORS 314.”
Sherwin-Williams Co. v. Dep't of Rev., 14 Or. Tax 384 (Or. T.C. 1998). · cites it 3× “610(7) provides that: “ ‘Sales’ means all gross receipts of the taxpayer not allocated under ORS 314.615 to 314.645.” Defendant disallowed the inclusion of gross receipts from Plaintiffs investment securities but did allow the income realized therefrom.”
Caterpillar Tractor Co. v. Dep't of Revenue, 618 P.2d 1261 (Or. 1980). · cites it 7× “The practice of combined reporting and the factors that trigger its applicability are described in the administrative rules implementing ORS 314.615. Basically, ORS 314.615 requires a taxpayer with income from interrelated business activity within and outside of the State of…”
Crocker Equip. Leasing, Inc. v. Dep't of Revenue, 838 P.2d 552 (Or. 1992). · cites it 2× “Financial organizations are excluded, by ORS 314.615, from the coverage of UDITPA.”
Atl. Richfield Co. v. Dep't of Revenue, 717 P.2d 613 (Or. 1986). · cites it 2× “ORS 314.615 provides that “[a]ny taxpayer having income from business activity which is taxable both within and without this state * * * shall allocate and apportion the net income of the taxpayer as provided in ORS 314.”
At&T Corp. v. Dep't of Revenue, 358 P.3d 973 (Or. 2015). “ORS 314.615. “Taxpayers engaged in activities as a financial organization or public utility shall report their income as provided in ORS 314.”
Stonebridge Life Ins. v. Dep't of Revenue, 18 Or. Tax 423 (Or. T.C. 2006). “610(4) (defining insurance companies as financial organizations); ORS 314.615 (requiring financial organizations to report income under ORS 314.”
Donald M. Drake Co. v. Dep't of Revenue, 4 Or. Tax 552 (Or. T.C. 1971). · cites it 6× “615-(B), in explication of ORS 314.615, defines “unitary business” and shows its impact upon the method of reporting.”
U.S. Bancorp v. Dep't of Revenue, 103 P.3d 85 (Or. 2004). “See ORS 314.615 (excluding financial organizations with taxable income from both within and outside Oregon from UDITPA).”
Health Net Life Ins. Co. v. Dept. of Rev., 24 Or. Tax 514 (Or. T.C. 2021). · cites it 2× “Those categories include insurers, public utilities, and finan- cial organizations (which are excluded from UDITPA by ORS 314.615 and are instead subject to apportionment under ORS 314.”
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