nowhere income

nowhere income (uncountable)

1. (US, accounting) Income that is generated in the United States by a corporation but that is not taxed by the destination US state (the state in which a buyer, for example, is based), due to the state not having the jurisdiction to tax the corporation.
   • 1979, Byron Dorgan, quotee, “Panel of State Tax Commissioners: Byron Dorgan, State Tax Commissioner, State of North Dakota, and Roboert Corcoran, Deputy Director, Department of Revenue, State of Montana”, in Interstate Taxation, S. 2173: Hearings before the Committee on the Judiciary United States Senate, Ninety-Fifth Congress, First and Second Sessions on Interstate Taxation, U.S. Government Printing Office, page 408:

     The bill seems to me, and I have not had a very careful reading of it, but it looks like a tax exemption for big business and it looks to me like it will assuredly create additional nowhere income for income tax purposes for corporations that are doing business in most of the States.

   • 2006, Dan Bucks, quotee, “Statement of Michael Mundaca, Partner, Ernst & Young, LLP, National Tax Department, International Tax Services, Washington, DC”, in How Much Should Borders Matter? Tax Jurisdiction in the New Economy: Hearing before the Subcommittee on International Trade of the Committee on Finance, United Sates Senate, One Hundred Ninth Congress, Second Session, U.S. Government Printing Office, page 28:

     In fact, the Congressional Research Service found, in its report on the issue of a physical presence nexus standard, that in many instances corporations could in fact produce large quantities of nowhere income, meaning that it is not taxed anywhere.

   • 2007, Donald Bruce, John Deskins, William F. Fox, “On the Extent, Growth, and Efficiency Consequences of State”, in Alan J. Auerbach, James R. Hines Jr., Joel Slemrod, editors, Taxing Corporate Income in the 21st Century, Cambridge University Press, →ISBN, page 235:

     A number of states use throwback rules to eliminate the nowhere income that arises because of P.L. 86-272.

• throwback
• throwout