Section 280-RICR-20-25-9.7 - Combined Reporting Requirement for Tax Years Beginning on or After January 1, 2015A. Commencement of Mandatory Unitary Combined Reporting. For tax years beginning on or after January 1, 2015, a C corporation must report on its Rhode Island corporate income tax return not only its own income, but also the combined income of the other corporations that are members in its combined group. The C corporation must treat all such corporations and affiliates as if they comprise one, single unitary company, and combine all income into a single pool. Thus, each member in the combined group must include all receipts, i.e., total receipts or gross receipts, from sales or other sources, without regard to whether the member has corporate income tax nexus in this state. In calculating the single sales factor for a combined group, receipts between members included in the group must be eliminated.B. Treatment of C Corporation's Pass-Through Entity Income. When a partnership or other pass-through entity does not elect to be taxed as a corporation for federal tax purposes and is directly or indirectly held by a corporation, including any member in a combined group, then the business conducted by the partnership or pass-through entity shall be considered the business of the corporation to the extent of the corporation's distributive share of the partnership or pass-through entity income. Such distributive share shall be included in the net income calculations of the corporation and the combined group, and shall be apportioned to Rhode Island for corporate income tax purposes as set forth in this Regulation, consistent with the decision reached by the Rhode Island Supreme Court in Homart Dev. Co. v. Norberg, 529 A.2d 115 (R.I. 1987).C. Single Sales Factor Apportionment. For purposes of combined reporting, a C corporation must use the single sales factor apportionment formula, as described in § 9.8 of this Part. The purpose of apportionment in the context of combined reporting is to determine the combined group's Rhode Island source income, which is taxable. In determining the combined group's taxable income in this manner, the Division of Taxation is merely measuring the in-state activities of the combined group, and not imposing a tax on members in the combined group that lack nexus with Rhode Island or that are protected from Rhode Island taxation by Public Law 86-272. After determining through such an apportionment formula the amount of a combined group's net income apportioned to Rhode Island, combined group net income is solely attributed to and tax is solely imposed on those members in the combined group that have corporate income tax nexus with Rhode Island. D. Members of the Combined Group with Different Accounting Periods:1. Mandatory Election of Uniform Accounting Period. If the taxable year of a member in a combined group differs from the taxable year of the combined group, the designated agent shall elect to determine the portion of that member's income to be included in one of the following ways: a. a separate income statement prepared from the books and records for the months included in the group's taxable year; orb. including all of the income for the year that ends during the group's taxable year.2. Year-to-Year Consistency Requirement. The same method must be used for each member with a different accounting period. Once an election is made under this section, it is the only method that may be used from year to year with respect to members in the combined group, except upon prior written approval of the Tax Administrator.280 R.I. Code R. § 280-RICR-20-25-9.7