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FTE-B, and FTE-C. Corporation 1 owns 40% of FTE-A; FTE’s total sales multiplied by the ratio of Michigan revenue
Corporation 2 owns 15% of FTE-A, and 35% of FTE-B; and miles over revenue miles everywhere as provided in the
Corporation 3 owns 45% of FTE-B. FTE-C is owned by FTE-A “Sourcing of Sales to Michigan” chart located in Form 4890.
(50%) and by FTE-B (30%). Thus, on column E, the group Revenue mile means the transportation for consideration of one
will enter “55.0000” for FTE-A (40% from Corporation A + net ton in weight or one passenger the distance of one mile.
15% from Corporation B); “80.0000” for FTE-B (35% from
NOTE: Only transportation services are sourced using revenue
Corporation 2 + 45% from Corporation 3); and “53.0000” for
miles. To the extent the taxpayer has business activities or
FTE-C (50% * 55% from Corporation 1 and Corporation 2 +
revenue streams not from transportation services, those
30% * 80% from Corporation 2 and Corporation 3).
receipts should be apportioned utilizing the sales factor.
UBGs: Enter on this line the percentage of this FTE that is
Column H: Enter on this line the Michigan sales made from
owned by the entire UBG. For example, if the UBG consists of
the FTE to the taxpayer and Michigan sales made by this FTE
three C Corporation members, each of which owns 20% of this
to another FTE that is unitary with the taxpayer and is included
FTE, the UBG owns 60% of this FTE. If the UBG is unitary
on this form.
with this FTE, enter “60.0000” on the corresponding line in
this column. UBGs: Elimination, where required, applies to sales from the
FTE to any member of the UBG as well as sales from the FTE
Column F: Enter the same Identifying Number in Column F
to another FTE that is unitary with the UBG. However, there
that was used for the corresponding FTE in Column A.
is elimination no for sales made to an otherwise related entity
Column G: Enter the Michigan sales that are directly if the related entity is excluded from the UBG. For example,
attributable to the FTE. consider a group with a U.S. parent, a U.S. subsidiary, and a
foreign operating entity subsidiary that would otherwise be
For a Michigan based FTE, all sales are Michigan sales unless
a UBG, but the foreign operating entity is excluded from the
the FTE is subject to tax in another state or foreign country. An
UBG by definition. The sales from an FTE that is unitary with
FTE is subject to a tax in another state or foreign country if the
the UBG to that foreign operating entity may not be eliminated.
FTE is subject to a business privilege tax, a net income tax, a
franchise tax measured by net income, a franchise tax for the Column J: For each FTE included on this form, multiply
privilege of doing business, acorporate stock tax, or if the state the amount entered in Column I by the percentage entered in
or foreign country has jurisdiction to subject the FTE to one or Column E. Add up all of the entries in Column J and enter
more of the above listed taxes. this amount on Line 9b of Form 4891. This is the amount of
proportionate Michigan sales from FTEs that are unitary
Sale or Sales means the amounts received by the FTE as
with the taxpayer that will be included in the taxpayer’s
consideration from the following:
apportionment calculation.
• The transfer of title to, or possession of, property that is
Column K: Enter the same Identifying Number in Column
stock in trade or other property of a kind which would
K that was used for the corresponding FTE in Column A and
properly be included in the inventory of the FTE if on hand
Column F.
at the close of the tax period, or property held by the FTE
primarily for sale to customers in the ordinary course of Column L: Enter the total sales that are directly attributable to
its trade or business. For intangible property, the amounts the FTE.
received will be limited to any gain received from the Transportation services that source sales based on revenue
disposition of that property. miles: Enter on this line the total sales that are directly
• Performance of services which constitute business activities. attributable to the FTE.
• The rental, leasing, licensing, or use of tangible or intangible Column M: Enter on this line the total sales made from
property, including interest, that constitutes business the FTE to the taxpayer and total sales made by this FTE to
activity. another FTE that is unitary with the taxpayer and is included
• Any combination of business activities described above. on this form.
• For FTEs not engaged in any other business activities, UBGs: Elimination, where required, applies to sales from the
sales include interest, dividends, and other income from FTE to any member of the UBG as well as sales from the FTE
investment assets and activities as well as from trading to another FTE that is unitary with the UBG. However, there
assets and activities. is elimination no for sales made to an otherwise related entity
Complete the Apportionment Calculation using amounts for the if the related entity is excluded from the UBG. For example,
FTE’s business activity only. Do not include amounts received consider a group with a U.S. parent, a U.S. subsidiary, and a
from a profits interest in a Partnership, S Corporation, or LLC. foreign operating entity subsidiary that would otherwise be
a UBG, but the foreign operating entity is excluded from the
Use the information in the “Sourcing of Sales to Michigan” UBG by definition. The sales from an FTE that is unitary with
section in Form 4890 to determine Michigan sales. the UBG to that foreign operating entity may not be eliminated.
For transportation services, which should generally source Column O: For each FTE included on this form, multiply the
sales receipts based on revenue miles, enter on this line the amount entered in Column N by the percentage entered in
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