Question:

Shielo Inc. has two divisions A & B in Colorado. A manufactures ink, and B manufactures computers. Shielo sells ink only on a wholesale basis to printer manufacturers in Colorado, but now plans to sell computers on a retail basis using salespeople in California. Shielo wants to limit the potential tax liability caused by nexus, and will pay $30,000 to a well-trained SALT advisor from CSULA.

a. To what law would you point Shielo with respect to its activities in California? What does the law say?

b. How can Shielo avoid tainted activities in California?

c. What do you tell Shielo with respect to a reorganization that might isolate its computer acctivities and limit possible apportionment of income under the Unitary Business concept?