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Oregon Revised Statutes

Or. Rev. Stat. § 314.650 (2026)

Apportionment of income

✓ current as of May 2026
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      314.650 Apportionment of income. All apportionable income shall be apportioned to this state by multiplying the income by the sales factor. [1965 c.152 §10; 1989 c.626 §5; 1989 c.1088 §1; 1995 c.79 §156; 2001 c.793 §1; 2003 c.739 §§1,5; 2005 c.832 §§48,49; 2009 c.842 §1; 2017 c.43 §4]

Notes of Decisions
Cited in 43 cases (6 in the last 5 years), 1970–2024 · leading case: Powerex Corp. v. Dep't of Revenue, 346 P.3d 476 (Or. 2015).
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Powerex Corp. v. Dep't of Revenue, 346 P.3d 476 (Or. 2015). · cites it 8× “See ORS 314.650. Specifically, for each tax year, a company’s sales “in this state” are divided by the company’s total sales to arrive at the sales factor.”
Tektronix, Inc. & Subsidiaries v. Dep't of Revenue, 316 P.3d 276 (Or. 2013). · cites it 7× “610(1)-(A)(2) (“‘Apportionment’ refers to the division of business income between states by the use of a formula containing apportionment factors.”
Oracle Corp. & Subsidiaries II v. Dept. of Rev., 24 Or. Tax 359 (Or. T.C. 2021). · cites it 4× “See ORS 314.650 (“All business income shall be apportioned to this state by multiplying the income by the sales factor.”
Crystal Commc'ns, Inc. v. Dep't of Revenue, 297 P.3d 1256 (Or. 2013). · cites it 2× “Specifically, one of those rules provides, “The provisions of ORS 314.650 [for apportioning business income] apply to all tax returns of financial organizations and public utilities for all tax years beginning on or after January 1, 1991.”
Twentieth Century-Fox Film Corp. v. Dep't of Revenue, 700 P.2d 1035 (Or. 1985). · cites it 3× “ORS 314.650 to 314.665. ORS 314.650 through 314.”
Health Net, Inc. v. Dept. of Rev., 22 Or. Tax 128 (Or. T.C. 2015). · cites it 7× “(8) In its original tax returns for the years at issue, taxpayer apportioned the Oregon component of its consoli- dated income by using the Oregon apportionment formula found at ORS 314.650, which includes a single sales fac- tor for apportionment.”
Atl. Richfield Co. v. Dep't of Revenue, 717 P.2d 613 (Or. 1986). · cites it 5× “” ORS 314.650 through 314.670 are the relevant apportionment statutes.”
Pennzoil Co. v. Dep't of Revenue, 33 P.3d 314 (Or. 2001). · cites it 2× “The Tax Court held that the proceeds were business income, subject to apportionment under ORS 314.650 (1987), 2 because: (1) the income arose from Pennzoil’s agreement with Getty Oil; (2) Pennzoil’s purpose in negotiating the Getty contract was to acquire some of Getty’s oil…”
Simpson Timber Co. v. Dep't of Revenue, 953 P.2d 366 (Or. 1998). · cites it 2× “[2] ORS 314.650 provides the formula for apportionment of business income of a multistate unitary enterprise, stating that "[a]ll business income shall be apportioned to this state by multiplying the income by a fraction" that accounts for the factors of relative value of…”
Gen. Dynamics Corp. v. Sharp, 919 S.W.2d 861 (Tex. App. 1996). “1993); Or.Rev.Stat. § 314.650 (1993); 72 Pa.Cons.”
At&T Corp. & Includible Subsidiaries v. Dep't of Revenue, 358 P.3d 973 (Or. 2015). “UDITPA § 9; compare ORS 314.650(1) (during the relevant tax years, Oregon doubled the sales factor before adding, and then divided by four).”
Oracle Corp. & Subsidiaries I v. Dept. of Rev., 24 Or. Tax 327 (Or. T.C. 2020). · cites it 3× “See ORS 314.650 (all business income to be apportioned to Oregon “by multiplying the income by the sales factor”).”
Show all 43 citing cases →
— Or. Rev. Stat. § 314.650(1) — 8 cases
Tektronix, Inc. & Subsidiaries v. Dep't of Revenue, 316 P.3d 276 (Or. 2013). “610(1)-(A)(2) (“‘Apportionment’ refers to the division of business income between states by the use of a formula containing apportionment factors.”
At&T Corp. & Includible Subsidiaries v. Dep't of Revenue, 358 P.3d 973 (Or. 2015). “UDITPA § 9; compare ORS 314.650(1) (during the relevant tax years, Oregon doubled the sales factor before adding, and then divided by four).”
Pennzoil Co. v. Dep't of Revenue, 33 P.3d 314 (Or. 2001). “The Tax Court held that the proceeds were business income, subject to apportionment under ORS 314.650 (1987), 2 because: (1) the income arose from Pennzoil’s agreement with Getty Oil; (2) Pennzoil’s purpose in negotiating the Getty contract was to acquire some of Getty’s oil…”
Comcast Corp. II v. Dept. of Rev. (TC 5265), 24 Or. Tax 250 (Or. T.C. 2020).
Pennzoil Co. v. Dep't of Revenue, 15 Or. Tax 101 (Or. T.C. 2000).
— Or. Rev. Stat. § 314.650(2) — 1 case
Terrace Tower U.S.A., Inc. v. Dep't of Revenue, 16 Or. Tax 131 (Or. T.C. 1999).
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