A survey of state income tax planning issues for international business activities.

Tax planners for multinational businesses need to be aware of the varied state income tax systems that these businesses may be subject to, and planners must ensure that tax considerations are integrated into corporate policies. The water's edge election available in some states can turn worldwide combined reporting from a tax burden to a planning opportunity if the planner is aware of the limitations of the election. States vary as to their tax treatment of foreign branch operations and whether dividends are included in the tax base used for apportionment.