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Oregon Revised Statutes

Or. Rev. Stat. § 314.655 (2026)

Determination of property factor

✓ current as of May 2026
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      314.655 Determination of property factor. (1) For purposes of ORS 317.391, 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.

      (2) Property owned by the taxpayer is valued at its original cost. Property rented by the taxpayer is valued at eight times the net annual rental rate. Net annual rental rate is the annual rental rate paid by the taxpayer less any annual rental rate received by the taxpayer from subrentals.

      (3) The average value of property shall be determined by averaging the values at the beginning and ending of the tax period but the Department of Revenue 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. [1965 c.152 §§11,12,13; 2001 c.793 §3; 2001 c.933 §2; 2009 c.842 §2]

Notes of Decisions
Cited in 18 cases (2 in the last 5 years), 1974–2024 · leading case: Atl. Richfield Co. v. Dep't of Revenue, 717 P.2d 613 (Or. 1986).
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Atl. Richfield Co. v. Dep't of Revenue, 717 P.2d 613 (Or. 1986). · cites it 7× “ORS 314.655 provides: “(1) 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…”
Twentieth Century-Fox Film Corp. v. Dep't of Revenue, 700 P.2d 1035 (Or. 1985). · cites it 2× “” ORS 314.655 “(1) 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…”
Comcast Corp. v. Dept. of Rev. (TC 5265), 22 Or. Tax 295 (Or. T.C. 2016). · cites it 2× “Defendant Department of Revenue (the department) requested a declaration that taxpayer was subject to subscriber apportionment under ORS 314.”
Crocker Equip. Leasing, Inc. v. Dep't of Revenue, 838 P.2d 552 (Or. 1992). · cites it 3× “280(F) incorporates by reference the UDITPA methodology used to determine the property (ORS 314.655), payroll (ORS 314.660), and sales (ORS 314.”
Tektronix, Inc. & Subsidiaries v. Dep't of Revenue, 316 P.3d 276 (Or. 2013). “ORS 314.655(1) (defining property factor); ORS 314.”
At&T Corp. & Includible Subsidiaries v. Dep't of Revenue, 358 P.3d 973 (Or. 2015). “See UDITPA §§ 10, 13, 15 (defining each factor); ORS 314.655 - 314.665 (Oregon’s version of those factors).”
U.S. Bancorp v. Dep't of Revenue, 103 P.3d 85 (Or. 2004). “280-(F) (1987) (incorporating UDITPA methodology for determining “property factor” set out in ORS 314.655 and its related rules). In addition to those provisions, during the relevant tax years, the department also imported restrictions from UDITPA that narrowly limited the…”
Atl. Richfield Co. v. Dep't of Revenue, 722 P.2d 727 (Or. 1986). · cites it 3× “In the absence of any indication that other UDITPA states apply ORS 314.655(2) as did the department and Tax Court, and in order to meet the UDITPA ‘uniformity’ criterion, we hold that IDCs should be included in ‘original cost.”
Equitable Sav. & Loan Ass'n v. Dep't of Revenue, 5 Or. Tax 661 (Or. T.C. 1974). “ORS 314.655. Many taxpayers engaged in interstate business own intangibles.”
Atl. Richfield Co. v. Dep't of Revenue, 9 Or. Tax 451 (Or. T.C. 1984). · cites it 5× “ORS 314.655, defining the property for purposes of apportionment of business income, states in relevant part: “(1) 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…”
Terrace Tower U.S.A., Inc. v. Dep't of Revenue, 16 Or. Tax 131 (Or. T.C. 1999). “ORS 314.655, ORS 314.660, and ORS 314.665.”
ABC Inc. v. Dept. of Rev. (Or. T.C. 2024). · cites it 4× “” ORS 314.655 to ORS 314.660; Or Laws 2005, ch 832, §§ 48-49 (making sales the sole factor for apportionment).”
Show all 18 citing cases →
— Or. Rev. Stat. § 314.655(1) — 3 cases
Tektronix, Inc. & Subsidiaries v. Dep't of Revenue, 316 P.3d 276 (Or. 2013). “ORS 314.655(1) (defining property factor); ORS 314.”
Atl. Richfield Co. v. Dep't of Revenue, 717 P.2d 613 (Or. 1986). “ORS 314.655 provides: “(1) 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…”
Mary Kay, Inc. v. Dep't of Revenue, 17 Or. Tax 91 (Or. T.C. 2003).
— Or. Rev. Stat. § 314.655(2) — 4 cases
Atl. Richfield Co. v. Dep't of Revenue, 717 P.2d 613 (Or. 1986). “ORS 314.655 provides: “(1) 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…”
Atl. Richfield Co. v. Dep't of Revenue, 722 P.2d 727 (Or. 1986). “In the absence of any indication that other UDITPA states apply ORS 314.655(2) as did the department and Tax Court, and in order to meet the UDITPA ‘uniformity’ criterion, we hold that IDCs should be included in ‘original cost.”
Atl. Richfield Co. v. Dep't of Revenue, 9 Or. Tax 451 (Or. T.C. 1984). “ORS 314.655, defining the property for purposes of apportionment of business income, states in relevant part: “(1) 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…”
Twentieth Century-Fox Film Corp. v. Dep't of Revenue, 9 Or. Tax 407 (Or. T.C. 1984).
— Or. Rev. Stat. § 314.655(4) — 1 case
Vesta Corp. v. Dept. of Rev. (Or. T.C. 2015).
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