Under Michigan’s Corporate Income Tax (CIT), a unitary business group is two or more United States “persons” who satisfy both a control test and one of two alternate relationship tests.
Revenue Administrative Bulletin 2013-1 elaborates on a number of issues pertaining to the control test and alternate relationship tests. Among the matters upon which it provides additional guidance are:
- What is the control test under the CIT?
- What are controlled groups of entities?
- How do voting agreements affect the control test?
- What special considerations exist in applying the relationship tests?
- What factors should be weighed in determining whether either relationship test is met?
Revenue Administrative Bulletin 2013-1 also provides many useful illustrative examples demonstrating the application of various tests and definitions to hypothetical scenarios.