Private Letter Ruling

Ruling Number:P-2016-011
Tax Type:Corporate Income Tax
Brief Description:Ending Two-Factor Apportionment Election Prior to End of 10 Year Period
Effective Date:08/15/2016
Approval Date:08/15/2016


August 15, 2016


Re: Kansas Income Tax


Your correspondence of August 9, 2016, has been referred to me for response. Thank you for your inquiry.

By your e-mail you have requested our advice regarding Kansas income tax. Specifically, your e-mail states:
In response to your inquiry, please be advised the answer to your question is “no”. There are no specific requirements that must be met prior to the Secretary of Revenue considering a request to end the two-factor apportionment election prior to the end of the 10-year period. Instead, each request is considered based on its on facts and circumstances, and decisions are made on a case-by-case basis.

I trust this information is of assistance. If I can be of further service, please feel free to contact me.


NOTE: This opinion letter is based solely on the facts provided in your request for advice. If material facts or information were not disclosed this letter is null and void. This letter will be revoked without further action by the Department if the statutes, administrative regulations, published revenue rulings, or court decisions that materially affect this opinion are changed.

Date Composed: 09/16/2016 Date Modified: 09/16/2016