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LIC-6.18 - Apportionment for Passenger Carriers

Administrative Rules Adopted by Revenue Bureau Pursuant to Rule-Making Authority


The percentage of net income apportioned to the City or County for air and ground passenger transportation (airline, bus, and rail) who do business within the City or County may be determined using either of the following methods:


a. Departure Method. The following formula applies for this method:


# Local Departures / # Departures Everywhere = Apportionment %

In the airline industry, different types of aircraft differentiate revenues (as with jumbo jets versus smaller planes). Airlines may determine apportionable revenues in the following manner:


            Type 1 plane gross revenues X % of local departures of Type 1 planes +

            Type 2 plane gross revenues X % of local departures of Type 2 planes, etc.


Example: Airline ZED has 100 departures locally during the year. Airline ZED has 5,000 departures during the year everywhere. This equates to an apportionment of 2%. However, Airline ZED receives a large portion of its income from flying jumbo jets out of Los Angeles and Seattle. Airline ZED has 2,000 departures everywhere which represent jumbo jets--only 10 of these jumbo jet departures are local departures. Therefore, Airline ZED may make the following apportionment determination: 

  Jumbo Jet Regular Jet Total
Everywhere Departures 2000 3000 5000
Local Departures 10 90 100
Local Percentage .5% (1/2 of 1%) 3% 2 % (average)
Gross Revenues 10,000,000 5,000,000 15,000,000
Local Revenues 50,000 150,000 200,000
200,000/15,000,000=Redetermined Apportionment: 1.3333%
b. Ticket Sales Method. Gross ticket sales sold for departures from City or County (including station sales, ticket agent sales, internet sales, etc.) is included in the numerator of the apportionment fraction as City or County income. Other City or County incomes from other activities must also be included in the numerator of the apportionment fraction. The denominator of the apportionment fraction is gross income everywhere. Gross income everywhere shall be defined as gross ticket sales everywhere plus all taxable incomes from all other activities.

Portland City Code Section 7.02.610 D.2.
Multnomah County Code Section 12.610 D.2.

Revised administrative rule adopted by Director of Revenue Bureau January 25, 2011 for tax years beginning on or after January 1, 2011.
Submitted for inclusion in PPD September 17, 2002.
Originally adopted as Bureau of Licenses Administrative Rule 610.93-8 November 23, 1993.

Table of Contents
LIC-6.01 - Payments Deemed to be Compensation to Owners
LIC-6.02 - Self-Employment Tax Deduction and Health Care Premium Deduction
LIC-6.03 - Change of Ownership During the Year and Calculation of the Compensation Allowance Deduction
LIC-6.04 - Patronage Dividends
LIC-6.05 - Short Periods Count as Tax Year
LIC-6.06 - Definition of Controlling Shareholders and Calculation of Number of Controlling Shareholders
LIC-6.07 - Treatment of Currently Taxed Pass-Through Income
LIC-6.08 - Partnerships - Partner Level Deduction Election
LIC-6.09 - Qualified Retirement Plans
LIC-6.10 - De Minimus Business Activity for Personal Services
LIC-6.11 - Apportionment of Gains and Incomes Due to Sale of a Business
LIC-6.12 - Business Activity and Apportionment of Sales of Tangible Personal Property
LIC-6.13 - De Minimus Business Activity for Tangible Personal Property
LIC-6.14 - Apportionment of Gross Income from Business Activities Other than Sales of Tangible Personal Property
LIC-6.15 - Apportionment for Banking Income
LIC-6.16 - Apportionment for Domestic Insurers
LIC-6.17 - Apportionment for Freight Carriers
LIC-6.18 - Apportionment for Passenger Carriers
LIC-6.19 - Apportionment for Incomes Subject to PCC Chapters 7.12 or 7.14
LIC-6.20 - Apportionment for Providers of Electronic or Telephonic Services