Form 4900 - Michigan Corporate Income Tax - Unitary Relationships With Flow-Through Entities - 2014 Page 3

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Instructions for Form 4900
Michigan Corporate Income Tax:
Unitary Relationships with Flow-Through Entities
operating entities) that are corporations, financial institutions
Purpose
or insurance companies that satisfy the control test and have
made the election to file as a UBG. Once the election is made,
To assist in calculating the apportionment factor of a taxpayer
that is unitary with one or more flow-through entities.
the Affiliated Group is treated as a UBG for all purposes.
For more information regarding the control and relationship
General Instructions
test, see the Treasury Web site at
This form is intended to only be used by a Corporate Income
and go to the “Withholding” section.
Tax (CIT) taxpayer that is unitary with one or more flow-
If the taxpayer is a UBG, fill out this form at the group level.
through entities. Included in this form will be flow-through
Specifically, as noted in the Column by Column Instructions,
entities that are unitary with the taxpayer and whose tax year
columns E must be filled out using data from the group as a
ends with or within the tax year included on the taxpayer’s CIT
whole.
Annual Return (Form 4891).
To determine whether the taxpayer and the flow-through entity
A flow-through entity is an entity that, for the applicable tax
satisfy the second requirement to be unitary with one another
year, is treated as a subchapter S Corporation under section
– that they satisfy either the Flow-of-Value or Integration Test
1362(a) of the internal revenue code, a general partnership, a
– apply the same concepts as used when determining whether
trust, a limited partnership, a limited liability partnership, or a
a UBG satisfies the Relationship Test as explained on the
limited liability company that is not taxed as a C Corporation
Treasury Web site at .
for federal income tax purposes.
NOTE: A flow-through entity owned directly or indirectly by
A taxpayer is unitary with a flow-through entity if the taxpayer:
a taxpayer may or may not be unitary with that taxpayer. This
• Owns or controls, directly or indirectly, more than 50% of
form asks for information only on the flow-through entities that
the ownership interests with voting rights (or ownership
are unitary with the taxpayer. For those flow-through entities
that are not unitary with the taxpayer, use the Non-Unitary
interests that confer comparable rights to voting rights) of
the flow-through entity; AND
Relationships with Flow-Through Entities (Form 4898).
• The taxpayer and flow-through entity have activities or
operations which result in a flow of value between the
Column-by-Column Instructions
taxpayer and the flow-through entity, or between the flow-
Columns not listed are explained on the form.
through entity and another flow-through entity unitary with
Name and Account Number: Enter the name and Federal
the taxpayer, or has business activities or operations that are
Employer Identification Number (FEIN) of the taxpayer as
integrated with, are dependant upon, or contribute to each
reported on page 1 of Form 4891.
other.
The determination of whether a taxpayer is unitary with a flow-
UBGs: Complete one Form 4900 for the entire group, and use
through entity is made at the taxpayer level. If the taxpayer
multiple copies of the form if reporting information on more
flow-through entities than space allows. Enter the Designated
at issue is a Unitary Business Group (UBG), the ownership
Member name in the Taxpayer Name field and the Designated
requirement will be made at the UBG level. Thus, if the
combined ownership of the flow-through entity by the UBG
Member’s Federal Employer Identification Number in the FEIN
box.
is greater than 50%, then the ownership requirement will be
satisfied.
Column A: In Column A, assign a number (beginning with
NOTE: PA 266 of 2013 authorizes an affiliated group
1 and numbering sequentially) to all flow-through entities
election that applies an alternate test for finding a unitary
that are unitary with the taxpayer. This same number must
relationship between corporations. This act DID NOT create
also be used in Columns F and K when referencing the same
a corresponding “affiliated group” test for finding a unitary
flow-through entity. (If using multiple copies of the form
relationship between a corporation and an FTE. The existence
the subsequent forms numbering should start with the next
of a unitary relationship between a corporation and an FTE is
sequential number from the previous completed form)
still based exclusively on the traditional two-part test described
Columns B and C: Identify each flow-through entity by name
above.
and FEIN.
A UBG is a group of United States C Corporations, insurance
Column D: Check this box if the flow-through entity has
companies, and financial institutions, other than a foreign
receipts from transportation services. To calculate Sales from
operating entity, that satisfies the control test and relationship
Transportation Services, see the instructions for Columns
test. If an Affiliated Group Election is made (see instructions
G and L and the table in the “Sourcing of Sales to Michigan”
for Form 4891), the UBG also includes all members of the
section of Form 4891.
affiliated group, as defined in IRC 1504 except that the group
Column E: Enter on this line the percentage of this flow-
includes only US persons (no foreign persons or foreign
69

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