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LIC-6.20 - Apportionment for Providers of Electronic or Telephonic Services

APPORTIONMENT FOR PROVIDERS OF ELECTRONIC OR TELEPHONIC SERVICES
Administrative Rules Adopted by Bureau of Licenses Pursuant to Rule-Making Authority
ARB-LIC-6.20

 
If the income of a service provider of electronic or telephonic services is derived from business activity occurring both within and without the City of Portland and/or Multnomah County, the gross income earned within the City or County shall be determined as earned at the situs of delivery and/or use of such services.
Example 1: Gross incomes from delivery and/or use of electronic or electrical signals shall be included in the numerator of the apportionment fraction for the City of Portland and/or Multnomah County if the location of the use of the electronic or electrical signals are within the City of Portland and/or Multnomah County.
 
Example 2: Gross incomes from the delivery and/or use of digital information other than general telephone services (such as computer services delivered via phone lines or coaxial cable) shall be included in the numerator of the apportionment fraction for Multnomah County and/or the City of Portland if such digital information is used within Multnomah County and/or the City of Portland.
 
Example 3: Gross incomes from the delivery and/or use of telephonic services generated by electromagnetic radiation (e.g., cell phones and satellite phones) shall be included in the numerator of the apportionment factor if the service is billed or paid from an address located within the City of Portland and/or Multnomah County. Note: Since cell phone usage is generally mobil in nature, it is assumed that usage will be uniform over boundaries, therefore, it is determined the most logical assignment of incomes is to the billing address of the user of such services.
 
Example 4: Gross incomes from the delivery and/or use of long distance telephone services shall be included in the numerator of the apportionment factor if the long distance call originates or terminates within the City of Portland and/or Multnomah County and is billed or paid from an address located within the City of Portland and/or Multnomah County.
Note: This rule shall be effective for all returns, including amended returns, filed on or after the date of adoption of this rule.

 
REFERENCES
 
Portland City Code Section 7.02.610 D.
 
Multnomah County Code Section 5.60.610 D.

 
HISTORY
Submitted for inclusion in PPD September 17, 2002.
Originally adopted as Bureau of Licenses Administrative Rule 610.99-1 December 28, 1999.

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