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Question: The state of Grace has no corporate income tax. It borders the state of Sin, which has a corporate income tax and a throwback rule identical to the one in UDITPA. Most corporations doing business in Grace have factories, offices, and stores located in both Grace and Sin. Many corporations ship goods from their warehouses in Sin to their stores in Grace, and vice versa. (Few, if any corps, operate exclusively in Grace.) A citizen's group in Grace, For the Children (FC), is urging Grace to enact a corporate income tax and use the proceeds to increase funding for education. FC claims that the new tax will not impose additional costs on most corporations; it will simply shift the taxes the corporations are already paying from Sin to Grace. FC says that, because Grace does not have a corporate income tax, Sin is effectively taxing income earned in Grace via its throwback rule. If Grace enacts a tax, then Sin's throwback rule will not be applicable (since the corporations will now be taxable in Grace) and corporate taxes in Sin will go down. FC says it is time "to stop letting Sin have Grace's slice of the tax revenue pie." Is FC correct? Would the new Grace tax be offset by a reduction in taxes in Sin? Why or why not? (Ignore issues of math, like rate differences between the Grace tax and the Sin tax. Instead, focus on whether FC's argument that Grace is letting Sin have its revenue via Sin's throwback rule is correct.)
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