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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.